“credit for TDS”

TDS / TCSSection 199Section 199603 judgments

The decision most relied on for credit for TDS is Dy. CIT v. Rohini Builders (127 Taxmann 523), cited in 162 judgments on BharatTax.

Leading authorities on credit for TDS

Dy. CIT v. Rohini Builders

127 Taxmann 523 · 2003 · High Court

162

citing judgments

An assessee is required to prove the identity, creditworthiness, and genuineness of a cash credit in their books of accounts, such as an unsecured loan, but is generally not required to prove the source of the source for such credits. Additions under Section 68 are deleted if sufficient proof of creditors, repayment, and TDS on interest is provided.

Trib.), and Noida Commercial Co-op. Bank Ltd. v. ITO(TDS)

64 Taxmann.com 158 · 2015 · Reported

citing judgments

A multi-state cooperative bank is obligated to deduct tax at source on interest paid or credited on fixed deposits placed by cooperative societies, as per Section 194A(1) read with Section 194A(3) of the Act, unless an exemption applies.

CIT v. JDS Apparels (P.) Ltd.

370 ITR 454 · 2015 · High Court

citing judgments

Payments to banks for credit card transaction processing are considered bank charges or fees for services rendered, not commission or brokerage, and therefore are not subject to TDS under Section 194H of the Income Tax Act.

CIT v. Bhooratnam & Co.

357 ITR 396 · 2013 · High Court

citing judgments

An assessee is entitled to credit for TDS even if the certificate is issued in the name of a joint venture or related party, provided the income to which the TDS relates is offered by the assessee. This principle emphasizes looking at the substance of the transaction over strict adherence to the name on the TDS certificate.

Escorts Ltd. v. DCIT

15 SOT 368 · 2007 · ITAT

citing judgments

An assessee is entitled to credit for Tax Deducted at Source (TDS) even if the income in respect of which TDS was deducted is not disclosed in the return. The Income-tax Department cannot deny TDS credit solely on the grounds that the income was not offered to tax.

Yashpal Sahni v. ACIT

293 ITR 539 · 2007 · High Court

citing judgments

Once tax has been deducted at source (TDS), the bar of section 205 applies, preventing the deductee from being asked to pay the tax again, even if the deductor fails to deposit the tax or issue TDS certificates.

Supreme Renewable Energy Ltd. v. ITO

3 ITR (Trib) 339 · 2010 · ITAT

citing judgments

Once Tax Deducted at Source (TDS) is deducted and paid to the Central Government, credit for such tax must be given to the assessee, irrespective of the assessment year to which it relates. This principle applies even to amended provisions of Section 199(1) of the Income Tax Act, 1961.

PCIT v. Shree Aradhana Urban Co-operative Credit Society Ltd.

172 Taxmann.com 537 · 2025 · High Court

citing judgments

A co-operative society is primarily a co-operative society, and therefore, it is not required to deduct tax at source on interest payments made on time deposits to other co-operative societies, by virtue of Section 194A(3)(v).

Judgments citing credit for TDS

Ashok Leyland Limited, Chennai vs. DCIT Company Circle 1 (1), Chennai

In the result, the appeal filed by the Revenue is partly allowed and the appeal filed by the assessee is partly allowed for statistical purposes

ITA 895/CHNY/2018[2009-10]Status: DisposedITAT Chennai05 Feb 2026AY 2009-10

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.895/Chny/2018 िनधा"रण वष"/Assessment Year: 2009-10 Ashok Leyland Limited, Vs. The Deputy Commissioner Of 1, Sardar Patel Road, Guindy, Income Tax, Chennai 600 032. Company Circle – Ltu, Chennai. [Pan: Aaaca4651L] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.945/Chny/2018 िनधा"रण वष"/Assessment Year: 2009-10 The Assistant Commissioner Of Vs. Ashok Leyland Limited, Income Tax, 1, Sardar Patel Road, Guindy, Large Taxpayer Unit – 2, Chennai. Chennai 600 032. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Assessee By : Shri Vikram Vijayaraghavan, Advocate (Virtual) ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Cit सुनवाई की तारीख/ Date Of Hearing : 10.11.2025 घोषणा की तारीख /Date Of Pronouncement : 05.02.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Cross Appeals Filed By The Assessee & The Revenue Are Directed Against The Order Dated 28.12.2017 Passed By The Ld.

For Appellant: Shri Vikram Vijayaraghavan, AdvocateFor Respondent: Shri AR V Sreenivasan, CIT

challenging the action of the ld. CIT(A) in not disposing the assessee’s submissions on the failure of the Assessing Officer grant credit for TDS Certificate. 46. We find no discussion whatsoever made by the Assessing Officer and the ld. CIT(A) in their respective orders. On perusal

Jayesh Darbi Collection, Solapur vs. Assistant Commissioner of Income Tax, Solapur

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 769/PUN/2025[2022-23]Status: DisposedITAT Pune04 Feb 2026AY 2022-23

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Pramod S ShingteFor Respondent: Shri Madhan Thirmanpalli

Section 143Section 143(1)

belongs to the firm but the CPC in the intimation order has allowed credit for TDS at Rs 11,652/-as against the amount of Rs 99,984/- claimed by the appellant. 5.4 Thus, considering the facts of the case, the AO is directed to grant the appellant an opportunity

Karthik Lakshman, Chennai vs. Iyo, Intl Taxationward-1(2), Chennai

In the result, appeal of the assessee is allowed

ITA 2182/CHNY/2025[2024-25]Status: DisposedITAT Chennai30 Jan 2026AY 2024-25

Bench: Shri George George Kand Ms. Padmavathy.Sआयकर अपील सं./Ita No.2182/Chny/2025 िनधा"रण वष" /Assessment Year: 2024-25

For Respondent: Ms. R.Kavitha, Addl. CIT

Section 143(1)Section 205Section 250

income for A.Y 2024-25 on 25.12.2024. The return was processed u/s. 143(1) of the Act in Karthik Lakshman :- 2 -: which the credit for TDS to the tune of Rs. 68,99,266/- deducted on salary by the employer M/s. Think and Learn Pvt. Ltd. (Byjus) that ... Satyaraj v. ACIT [ITA No.1529/Chny/2023 dated 30.04.2024] where it is held that: “4. The only issue before us is whether the tax credit on TDS made by the deductor not remitted to the department and also, it is not available in Form 26AS can still be given credit

Canara Goods Transport, Mangalore vs. ACIT, Circle-1(1)& Tps, Mangalore

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 2078/BANG/2025[2016-17]Status: DisposedITAT Bangalore30 Jan 2026AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessmentyear: 2016-17 M/S. Canara Goods Transport, 10-7-255/3, Bibi Alabi Road Bunder, Acit, Mangaluru – 575 001, Vs. Circle-1(1) & Tps, Karnataka. Chennai. Pan No : Aacfc9460E Appellant Respondent Appellant By : Smt. Sheetal Borkar, Advocate Respondent By : Sri Ganesh R Ghale, Advocate – Standing Counsel For Revenue Date Of Hearing : 29.01.2026 Date Of Pronouncement : 30.01.2026

For Appellant: Smt. Sheetal Borkar, AdvocateFor Respondent: Sri Ganesh R Ghale, Advocate – Standing

Section 143(1)Section 143(2)Section 143(3)Section 250

audited financial statements. 4. The learned Add/JCIT(A) has overlooked the fact that, the learned Assessing Officer has failed to give credit of TDS as reflected in the Form 26AS. 5. The learned Add/JCIT(A) has grossly ignored the alternative plea of the appellant, that if it all undisclosed receipts ... undisclosed income, is upheld. Canara Goods Transport, Mangaluru Page 5 of 8 4.3 Further, the assessing officer is directed to9 give credit for TDS to the extent of Rs.46,352 i.e. the difference between TDS of 26AS per schedule 6 of the ITR Rs.6,20,791 and as per 26AS

Ajay Singh Bhadoria, Kanpur vs. ITO(1)(1), Kanpur

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 806/LKW/2025[2015-16]Status: DisposedITAT Lucknow29 Jan 2026AY 2015-16

Bench: Shri Anadee Nath Misshra

Section 143(3)Section 144Section 44A

receipts/fee/turnover have been correctly offered for tax and whether refund claim is justified. In the aforesaid assessment order, the Assessing Officer also denied credit for TDS amounting to Rs.1,77,139/- out of total claim of TDS amounting to Rs.10,03,289/-. The assessee’s appeal was disposed

Zydus Lifesciences Ltd., Ahmedabad vs. The Dy.CIT, Central Circle-2(1), Ahmedabad

In the result, appeal filed by the assessee is partly allowed for statistical purposes

ITA 392/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad29 Jan 2026AY 2017-18

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), Ms. SUCHITRA KAMBLE (Judicial Member)

For Appellant: Shri Mukesh Patel, Shri Ajit KumarFor Respondent: Shri Prathvi Raj Meena, CIT.DR

Section 153(4)Section 153CSection 35Section 35(1)(i)Section 35(1)(iv)Section 92CSection 92C(2)

equivalence Study of Rs. 3,73,40,000/- 11. That the learned Assessing Officer erred in law and on facts in allowing short credit for TDS and TCS of Rs 9,02,68,127/- in the tax computation even though duly granted under an intimation processed

Ajith M Kumar, Bangalore vs. DCIT, Circle-3(3)(1), Bangalore

In the result, Appeal filed by the Assessee is allowed for statistical purposes

ITA 2389/BANG/2025[2018-19]Status: DisposedITAT Bangalore27 Jan 2026AY 2018-19

Bench: Shri Prashant Maharishi, Vice – & Shri Keshav Dubeyassessment Year : 2018-19

For Appellant: Ms. Susan Mathew, CAFor Respondent: Standing Counsel for Revenue

Section 133(6)Section 144Section 147Section 148Section 15Section 80Section 80ASection 80C

passed the Assessment Order wherein the total income of the Assessee from salary was assessed at Rs. 37,98,390/- and further no credit for TDS was granted. 3. The Assessee preferred an Appeal before the Ld. CIT(A) wherein he filed a detailed written statement stating that

Shreyas Paradkar, Mira Road vs. ITO 1(1) Thane, Thane

In the result, Assessee’s appeal is dismissed

ITA 4721/MUM/2025[2023-2024]Status: DisposedITAT Mumbai23 Jan 2026AY 2023-2024

Bench: Shri Narender Kumar Choudhryassessment Year: 2023-24 Shreyas Paradkar (Individual), Ito Range 1(1), C/O Ca Rahul Godbole & Ashar I.T. Park, 6Th Floor, Vs. Associates, 204, Spectra, Kothrud, Road No. 162, Wagle Indl. Pune – 411038. Estate, Pan- Cvzpp8788C Thane – 400604. (Appellant) (Respondent) Present For: Assessee By : Shir H.V. Datar, (Virtually Present) Revenue By : Shri Vinod Kumar V., Sr. D.R. Date Of Hearing : 20.11.2025 Date Of Pronouncement : 23.01.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 09.06.2025, Impugned Herein, Passed By Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2023-24. 2. In The Instant Case, The Assessee Has Claimed That He Opted For The New Tax Regime While Filing His Return Of Income On 25Th July 2023 By Entering All The Data On The Income-Tax Website. On Selecting The New Tax Regime, The Income-Tax Website Showed Tax Payable At ₹5,000 After Giving Credit For Tds & Therefore, The Assessee Paid The Respective Tax Payable & Submitted The Itr. The Assessee, On The Last Page Of The Itr, Computed The Tax As Per The New Regime, But Somehow, On The First Page Of The Return Of Income Filed, It Is Shown That The Assessee Did Not Opt For The New Tax Regime. This Was A Glitch On The Website, But Somehow, The Return Filed By The Assessee Was Processed Vide Intimation Dated 29.12.2023, Whereby The Taxable Income And/Or Return Filed By The Assessee Was Computed As Per The Old Regime & Not As Per The New Tax Regime Mainly For The Reason That The Assessee Failed To File The Relevant 2 Shreyas Paradkar (Individual)

For Appellant: Shir H.V. Datar, (Virtually Present)For Respondent: Shri Vinod Kumar V., SR. D.R

Section 115BSection 139(1)Section 143(1)Section 154Section 250

income-tax website. On selecting the new tax regime, the income-tax website showed tax payable at ₹5,000 after giving credit for TDS, and therefore, the Assessee paid the respective tax payable and submitted the ITR. The assessee, on the last page of the ITR, computed

Vaibhav Mittal, Jaipur vs. DCIT/ACIT 4(1), Ind, Indore

Appeal is dismissed

ITA 582/IND/2025[2012-13]Status: DisposedITAT Indore21 Jan 2026AY 2012-13

Bench: Shri Siddhartha Nautiyal

Section 133(6)Section 142(1)Section 144Section 147Section 148Section 154Section 69A

unexplained deposits in bank a/c of Rs. 1,26,037/- u/s 69A. Further, the AO did not allow credit of TDS deducted by employer out of salary income. Subsequently, the assessee filed a rectification-application u/s 154 to AO against assessment-order. The AO disposed of assessee’s application vide ... rectification-order dated 01.09.2021 giving credit of TDS out of salary income. However, in the rectification-order so passed, the AO did not make any discussion/rectification qua the addition of Rs. 1,26,037/- u/s 69A. Page 2 of 8 (iii) Vaibhav Mittal ITA No. 582/Ind/2025 - AY 2012-13 Further

Dharamvir Khosla vs. DCIT CC-5, New Delhi

ITA 3977/DEL/2025[2020-21]Status: DisposedITAT Delhi21 Jan 2026AY 2020-21

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: Sh. Rajiv Saxena, AdvFor Respondent: Sh. Mahesh Kumar, CIT, DR

Section 139Section 139(1)Section 143(1)Section 153CSection 32(1)(ii)

Dharamvir Khosla vs. DCIT CC-5, New Delhi

ITA 3976/DEL/2025[2019-20]Status: DisposedITAT Delhi21 Jan 2026AY 2019-20

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: Sh. Rajiv Saxena, AdvFor Respondent: Sh. Mahesh Kumar, CIT, DR

Section 139Section 139(1)Section 143(1)Section 153CSection 32(1)(ii)

3977/Del/2025 DharamvirKhosla (AY: 2019-20 & 2020-21) with government, recovery proceeding could only be initiated against deductor and not against the assessee-deductee. Credit for TDS could not be denied to assessee. Para 28 of the decision of BDR Finvest Pvt. Limited. In the case of Chintan Bindra ... claim at Page 3 of the computation of income prepared by AO the amount allowed as TDS was only Rs.8,14,748/-. Thus, credit for TDS amounting to Rs.17,03,974/- was not given as raised in ground No.3. Thus, here again AO did not apply his own mind

Hasbro Sa, Switzerland vs. Deputy Commissioner of Income Tax (International Tax), Circle 1(1)(1), Delhi, New Delhi

In the result, appeal filed by the assessee is allowed with above directions for statistical purposes

ITA 2842/DEL/2025[2020-21]Status: DisposedITAT Delhi21 Jan 2026AY 2020-21

Bench: Shri Ramit Kochar & Shri Raj Kumar Chauhan

Section 139(4)Section 143(1)Section 154Section 199Section 250

Bengaluru (AO). In the said intimation, the total income of the appellant has been assessed at INR 2,11,46,750/- and the credit of TDS amount of Rs. 21,14,675/- has not been granted. As a result, the demand of Rs. 27,07,820 including interest was raised ... intimation, the appellant had filed an application for rectification u/s 154 of the Act before the AO. The said application was dismissed and credit of TDS amount of Rs. 21,14,675/- has not been granted. The appellant challenged the said order

DCIT, Cir-5(1), Kolkata vs. M/S Coal India Ltd., Kolkata

ITA 1697/KOL/2019[2014-15]Status: DisposedITAT Kolkata20 Jan 2026AY 2014-15

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115JSection 250

been credited by the assessee in the profit and loss account though the same were reflected in Form No. 26AS and the credit of TDS had been given to the assessee. The transaction related to interest from Bank of India amounting to ₹1,92,32,107/- on which TDS ... noted that the assessee had not been able to substantiate as to how the income did not belong to it although the credit for TDS had been availed, the heads of income being interest and rent and the assessee having not made any attempt to controvert the finding

DCIT, Cir-5(1), Kolkata vs. M/S Coal India Ltd., Kolkata

In the result, the Revenue’s appeal in ITA No

ITA 1696/KOL/2019[2013-14]Status: DisposedITAT Kolkata20 Jan 2026AY 2013-14

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115JSection 250

been credited by the assessee in the profit and loss account though the same were reflected in Form No. 26AS and the credit of TDS had been given to the assessee. The transaction related to interest from Bank of India amounting to 71,92,32,107/- on which TDS ... noted that the assessee had not been able o substantiate as to how the income did not belong to it although the credit for TDS had been availed, the heads of income being interest and rent and the assessee having not made any attempt to controvert the finding

M/S. Coal India Limited, Kolkata vs. DCIT, Circle - 5(1), Kolkata

In the result, the Revenue’s appeal in ITA No

ITA 1406/KOL/2019[2013-14]Status: DisposedITAT Kolkata20 Jan 2026AY 2013-14

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115JSection 250

been credited by the assessee in the profit and loss account though the same were reflected in Form No. 26AS and the credit of TDS had been given to the assessee. The transaction related to interest from Bank of India amounting to 71,92,32,107/- on which TDS ... noted that the assessee had not been able o substantiate as to how the income did not belong to it although the credit for TDS had been availed, the heads of income being interest and rent and the assessee having not made any attempt to controvert the finding

DCIT, Circle - 5(1), Kolkata vs. M/S. Coal India Limited, Kolkata

ITA 623/KOL/2018[2012-13]Status: DisposedITAT Kolkata20 Jan 2026AY 2012-13

Section 115JSection 250

DCIT, Circle - 5(1), Kolkata vs. M/S. Coal India Limited, Kolkata

ITA 622/KOL/2018[2011-12]Status: DisposedITAT Kolkata20 Jan 2026AY 2011-12

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115JSection 250

Coal India Limited, Kolkata vs. DCIT, Circle - 5(1), Kolkata

ITA 467/KOL/2018[2012-13]Status: DisposedITAT Kolkata20 Jan 2026AY 2012-13

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115JSection 250

Sanjay Gopaldas Bajaj, Mumbai vs. ITO Ward-12(1)(1), Mumbai

ITA 5944/MUM/2025[2015-16]Status: DisposedITAT Mumbai20 Jan 2026AY 2015-16

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant ()

Section 139Section 139(1)Section 54

correctly shown the rental incomes of the two co owned properties in the return of income filed by him and had correctly claimed credit for TDS in respect of his co- owned share. The AO incorrectly made an observation in respect of making an addition

Abhishek Jayketu Joshi, Mumbai vs. Ac Cir-42(2)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 5775/MUM/2025[2019-20]Status: DisposedITAT Mumbai13 Jan 2026AY 2019-20

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokarabhishek Jayketu Joshi Ac Cir-42(2)(1), C-73, Venus Society, R. G. Kautilya Bhavan, Thadani Marg, Worli Sea Vs. Mumbai-400 051 Face, Mumbai-400 018 Pan/Gir No. Ackpj8583H (Applicant) (Respondent) Assessee By Shri M. M. Golvala, Ld. Ar Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 07.01.2026 Date Of Pronouncement 13.01.2026

Section 132Section 132(4)Section 139(1)Section 139(5)Section 143(1)Section 144BSection 147Section 148Section 148ASection 250

alia, the assumption of jurisdiction under section 147, the disallowance of deduction under section 80GGC, denial of cross-examination, and non-grant of credit for TDS, advance tax, and TCS. The assessee filed written submissions reiterating that the statutory conditions of section 80GGC were 5 Abhishek Jayketu Joshi duly fulfilled ... that the donation was bogus and that money in any form was returned to the appellant. 9. The AO erred in not granting credit for TDS amounting to Rs.5151547/- inspite of same appearing in form 26AS, and inspite of CPC granting the said credit in the intimation under section