“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

Madhu Kumar Patel, Hyderabad vs. ADIT, (Int. Taxn)-2, Hyderabad

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

ITA 395/HYD/2022[2015-16]Status: DisposedITAT Hyderabad26 Dec 2022AY 2015-16

Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year:2015-16 Shri Madhu Kumar Patel Vs. A.D.I.T (Intl.Taxation)-2 Hyderabad Hyderabad Pan:Bvdpp3797G (Appellant) (Respondent) Assessee By: Shri K.A. Sai Prasad, Ca Revenue By: Shri Rajendra Kumar, Cit(Dr) Date Of Hearing: 10/11/2022 Date Of Pronouncement: 26/12/2022 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 19.7.2022 Passed U/S 147 R.W.S. 144C(13) Of The I.T. Act For The A.Y 2015-16. 2. Facts Of The Case, In Brief, Are That The Assessee Is An Individual & A Resident Of The U.K. He Filed His Return Of Income On 31.08.2015 Declaring Total Income At Rs.2,91,07,000/- As Income From Long Term Capital Gain.

For Appellant: Shri K.A. Sai Prasad, CAFor Respondent: Shri Rajendra Kumar, CIT(DR)

Section 147Section 148Section 2(47)(v)

earlier assessment year. 6. A combined reading of Section 199(3) r.w. Rule 37BA(3) makes the position of law clear that credit for TDS is available in the year in which the income is reported and as a corollary, should not be deferred to some other assessment year ... same vein, however, we note that no positive finding of the Revenue Authorities below is available to show as to whether tax credit for TDS reflected in form No. 26AS in Assessment Year 2017-18 has been claimed or otherwise in that assessment year. A verification of factual position

Gundecha Construction Private Limited, Mumbai vs. National Faceless Appeal Centre, Mumbai

ITA 2521/MUM/2022[2014-2015]Status: DisposedITAT Mumbai23 Dec 2022AY 2014-2015

Bench: Shri Kuldip Singh & Shri S. Rifaur Rahmanassessment Year: 2014-15

For Appellant: Shri Vimal Punmiya, A.RFor Respondent: Mrs. Agnes P. Thomas, D.R

Section 143(1)

grounds inter-alia that :- 2 M/s. Gundecha Construction Pvt. Ltd. “1. LD. CIT(A) erred in redirecting the issue of the non credit of TDS back to the assessing officer without appreciating the facts and the documents furnished clearly indicating that the assessee has declared the income in its returns ... which was processed under section 143(1) ) of the Income Tax Act,1961 (for short ‘the Act’) vide order dated 22.07.2015 but credit of TDS of Rs.34,43,640/- was not given to the assessee as claimed by the assessee in its return of income. 3. Assessee carried the matter

Dboi Global Services P. Ltd., Mumbai vs. Addl/Jt/Dy/Asstt/CIT/ITO, Nationa E-Assessment Centre, Delhi

In the result, the appeal filed by the assessee is partly allowed

ITA 1263/MUM/2021[2016-17]Status: DisposedITAT Mumbai23 Dec 2022AY 2016-17

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal, Jm Deutsche India Pvt. Ltd [ Formerly Dboi Global Services Addl/Jt/Dy/Assit/Cit/Ito, Ltd] Block B-4, Level-6, National E-Assessment Vs. Nirlon Knowledge Park, Centre, New Delhi-110 003 Western Express Highway, Goregoan East, Mumbai-400 063 (Appellant) (Respondent) Pan No. Aaccd2953L

For Appellant: Shri Jehnagir D. MistriFor Respondent: Dr. Yogesh Kamat, CIT DR

Section 115JSection 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 155JSection 234BSection 234C

appellant pray that the Assessing Officer be directed to delete the above addition. 4. The AO erred in granting credit for TDS of ₹ 04,36,59,431/- as against ₹ 04,39,39,473/- claimed by the Appellant‟s in the return of income thereby granting short credit of TDS amounting ... profit. Accordingly, ground no.3 of the appeal is allowed. 016. Ground no 4 of appeal is with respect to the short grant of credit for TDS of ₹2,80,00,042/-. The same ground of appeal was not pressed at the time of hearing and therefore, same is dismissed. DBOI

Asst CIT Cir 4(3)(2), Mumbai vs. Morgan Stanley India Co.P.Ltd, Mumbai

ITA 1794/MUM/2016[2011-12]Status: DisposedITAT Mumbai15 Dec 2022AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Co No. 145/Mum/2016 (Arising In Ita No. 1794/Mum/2016 For A.Y. 11-12)

For Appellant: Shri Sunil M. Lala, ARFor Respondent: Shri Samuel Pitta, DR

Section 143(3)Section 144CSection 14ASection 253Section 80G

Rules. Ground 2: Short grant of credit for Taxes Deducted at Source (TDS) 3. The learned AO has erred in granting credit for TDS amounting to only for Rs 17,09,87,733 as against the amount to which the Appellant is entitled ... regarding deduction under Section 80G of the Act and therefore same is dismissed. 016. With respect to ground no.2, the grievance is that credit for TDS amounting to ₹17,24,18,686/- was claimed but was allowed only to the extent of ₹17,09,87,738/-. Though, nothing is argued

Morgan Stanley India Company P. Ltd, Mumbai vs. Asst CIT RG 4(3)(2), Mumbai

ITA 1715/MUM/2016[2011-12]Status: DisposedITAT Mumbai15 Dec 2022AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Co No. 145/Mum/2016 (Arising In Ita No. 1794/Mum/2016 For A.Y. 11-12)

For Appellant: Shri Sunil M. Lala, ARFor Respondent: Shri Samuel Pitta, DR

Section 143(3)Section 144CSection 14ASection 253Section 80G

Raymond Ltd, Mumbai vs. DCIT (OSD) RG 2(3), Mumbai

Accordingly, the same are dismissed as not pressed

ITA 4322/MUM/2012[2008-09]Status: DisposedITAT Mumbai12 Dec 2022AY 2008-09

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleraymond Limited V. The Addl. Cit– 2(3) New Hind House Aayakar Bhavan, M.K. Road Narottam Morarjee Marg Mumbai - 400020 Ballard Estate, Mumbai - 400001 Pan: Aaacr4896A Appellant Respondent C.O. No. 287/Mum/2017 [Arising Out Of Ita No. 2218/Mum/2011 (A.Y. 2007-08)] The Addl. Cit– 2(3) V. Raymond Limited Aayakar Bhavan, M.K. Road New Hind House Mumbai - 400020 Narottam Morarjee Marg Ballard Estate, Mumbai - 400001 Pan: Aaacr4896A Appellant Respondent M/S. Raymond Limited V. The Dcit – Osd- 2(3) New Hind House, Aayakar Bhavan, M.K. Road Narottam Morarjee Marg Mumbai – 400020 Ballard Estate, Mumbai - 400001 Pan: Aaacr4896A Appellant Respondent

Section 14A

rate was between Rs.190 to Rs.220 per sq. 5. The Learned Commissioner of Income tax (Appeals) erred in not giving direction regarding giving credit for TDS certificates amounting to Rs. 98,09,238/- 5 ITA No. 4322/MUM/2012 (A.Y. 2008-09) C.O. NO. 287& 288/MUM/2017 M/s. Raymond Limited 6. The appellant ... plugin sales Ltd.; d. to the disallowance made of rent expenses under section 40A(2)(b) of the Act: e. to give credit for TDS certificates amounting to Rs. 98,09,238/- and to modify the assessment in accordance with the provisions of the Act. 7. Each of the above

Raymond Ltd, Mumbai vs. Addl CIT RG 2(3), Mumbai

Accordingly, the same are dismissed as not pressed

ITA 2218/MUM/2011[2007-08]Status: DisposedITAT Mumbai12 Dec 2022AY 2007-08

Section 14A

Hp India Sales Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle-3(1)(1), Bangalore

In the result, ground 14 is allowed for statistical purposes

ITA 283/BANG/2022[2017-18]Status: DisposedITAT Bangalore07 Dec 2022AY 2017-18

Bench: Shri George George K, Jm & Shri Laxmi Prasad Sahu, Am It(Tp)A No.283/Bang/2022 : Asst.Year 2017-2018 M/S.Hp India Sales Private Ltd. The Assistant Commissioner No.24, Salarpuria Arena Of Income-Tax, Circle 3(1)(1) V. Bangalore. Hosur Main Road Adugodi Bengaluru – 560 030. Pan : Aaacc9862F. (Appellant) (Respondent) Appellant By : Sri.Ajay Vohra, Advocate Respondent By : Sri.Arun Kumar, Cit(Tp)-2-Dr Date Of Pronouncement : 07.12.2022 Date Of Hearing : 06.12.2022 O R D E R Per George George K, Jm : This Appeal At The Instance Of The Assessee Is Directed Against Final Assessment Order Dated 28.02.2022 Passed U/S 143(3) R.W.S. 144C(13) Of The I.T.Act. The Relevant Assessment Year Is 2017-2018. 2. The Assessee Has Raised 13 Grounds In Its Memorandum Of Appeal Dated 22.06.2022. The Learned Ar During The Course Of Hearing, Did Not Raise Any Specific Plea With Regard To Grounds 1 To 5, 10, 12 & 13 (Also Sub-Grounds), Hence, The Same Are Dismissed. The Surviving Grounds, Namely, Grounds 6 To 9, 11 & Its Sub-Grounds, Read As Follows:-

For Appellant: Sri.Ajay Vohra, AdvocateFor Respondent: Sri.Arun Kumar, CIT(TP)-2-DR

Section 143(3)Section 37Section 92B

Private Limited Ground No, 11: Short grant of credit for tax deducted at source (TDS) 11.1 The AO erred in not allowing appropriate credit for TDS as claimed by the Appellant. 11.2 The AO erred in granting credit for TDS only to the extent ... ordered accordingly. Ground 11 (Corporate Tax Issue) 10. In the above ground, it is claimed that the A.O. has not allowed appropriate credit for TDS as claimed by the assessee. The issue raised in ground 11 is restored to the files of the A.O. to examine the matter and grant

Dy CIT - 26(1), Mumbai vs. M/S. Pratibha China State Joint Venture Universal Majextic, Mumbai

In the result appeal of the Revenue is dismissed

ITA 468/MUM/2021[2014-15]Status: DisposedITAT Mumbai29 Nov 2022AY 2014-15

Bench: Shri Aby T Varkey, Jm & Shri S Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No.468 /Mum/2021 (निर्धारण वर्ा / Assessment Year: 2014-15) बिधम/ Dy. Commissioner Of Income Tax-26(1) M/S Pratibha China State Room No 623, 6Th Floor, Kautilya Bhavan, Joint Venture Vs. Universal Majestic, 14Th Bandra Kurla Complex Bandra East, Mumbai-400051 Floor, Off Eastern Expressway, Ghatkopar Mankhud Link Road, Govandi, Mumbai-400043 स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aabap0740 (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: None Revenue By: Mr. Hiren Bhatt, Sr Ar सुनवाई की तारीख / Date Of Hearing: 31/10/2022 घोषणा की तारीख /Date Of Pronouncement: 29/11/2022 आदेश / O R D E R Per Aby T. Varkey, Jm:

For Appellant: NoneFor Respondent: Mr. Hiren Bhatt, Sr AR

Section 143(2)Section 145

justification." 4"On the facts and in the circumstances of the case, the Ld.CIT(A) is right in derecting the AO to allow credit for TDS, where the turnover has not been offered for taxation by the assessee." 5"The appellant prays that the order

DCIT-2(2)(1), Mumbai vs. The Indian Hotels Company Ltd., Mumbai

In the result, appeal of the Assessee is partly allowed whereas the appeal of the Revenue is dismissed

ITA 3022/MUM/2016[2011-12]Status: DisposedITAT Mumbai29 Nov 2022AY 2011-12

For Appellant: Sh. Kanchan Kaushal, Sh. PratikFor Respondent: Dr. Yogesh Kamat

Section 115JSection 143(3)Section 144CSection 144C(13)Section 144C(5)Section 14ASection 36(1)(iii)Section 40Section 92C

Collected at Source (TCS) amounting to Rs. 2,06,85,052. It is prayed that the learned AO be directed to grant credit for TDS and TCS amounting to Rs.2,06,85,502.” 25. In Ground No. 11 the Assessee seeking directions for grant of credit of Tax Deducted ... learned AO be directed to compute interest under Section 244A of the Act upto the date of issue of refund and after considering credit for TDS and TCS as prayed in Ground No. 11 above.” 27. Ground No 12 pertains to levying of excess interest under Section 244A

The Indian Hotels Company Ltd., Mumbai vs. DCIT Cir. 2(2)(1), Mumbai

In the result, appeal of the Assessee is partly allowed whereas the appeal of the Revenue is dismissed

ITA 2308/MUM/2016[2011-12]Status: DisposedITAT Mumbai29 Nov 2022AY 2011-12

For Appellant: Sh. Kanchan Kaushal, Sh. PratikFor Respondent: Dr. Yogesh Kamat

Section 115JSection 143(3)Section 144CSection 144C(13)Section 144C(5)Section 14ASection 36(1)(iii)Section 40Section 92C

Renaissance Services Bv, Mumbai vs. DCIT (International Tax) 4(1) (1), Mumbai

In the result, appeal filed by assessee is allowed

ITA 1526/MUM/2021[2016-17]Status: DisposedITAT Mumbai25 Nov 2022AY 2016-17

Bench: Shri Vikas Awasthy & Shri Gagan Goyalrenaissance Services Bv, C/O Marriott Hotels India Pvt. Ltd. 303A, 304, Fulcrum, B-Wing, Hiranandani Business Park, Sahar Road, Andheri (East), Mumbai-400099 Pan: Aaecr4995E ...... Appellant Vs. Dcit (International Taxation)-4(1)(1), 17Th Floor, Room No. 1712, Air India Building, Nariman Point, Mumbai-400021 ..... Respondent

For Appellant: Sh. Paras Savla/Pratik PoddarFor Respondent: Sh. Soumendu Kumar Dash- Sr. DR

Section 143(2)Section 250Section 9(1)(vi)Section 9(1)(vii)

been claimed, are higher than the total of the receipts shown under all heads of income, in the return of income. Thus, while credit for TDS has been claimed, the corresponding receipts are not offered in the respective income schedules, to arrive at the taxable total income. Hence, the return

United Arab Shipping Company Ltd.(Formerly Known As United Arab Shipping Company (S.A.G)), Mumbai vs. DCIT (It)- 4(3)(1), Mumbai

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

ITA 2254/MUM/2022[2018-2019]Status: DisposedITAT Mumbai16 Nov 2022AY 2018-2019

Section 143(3)Section 144C(5)Section 234DSection 270ASection 90(2)

report vide letter dated 23/03/2022 by observing as under:- “It is further humbly submitted, that as per the extant guidelines of the CBDT, credit for TDS can be allowed only to the extent it reflects in 26AS/ITD System. In the instant case, the TDS reflected in the ITD system ... filing of the return/errors in the TDS deduction statements filed by the deductors. The only course available in this situation, for obtaining short credit of TDS is that the concerned deductors should be approached by the assessee for filing correction statements so as to reflect true TDS credits

Rajdeep Marketing Pvt. Ltd., Mumbai vs. ITO, WD. 3(3)(1), Mumbai

In the result, the appeal filed by the assessee is allowed

ITA 2053/MUM/2022[2012-13]Status: DisposedITAT Mumbai07 Nov 2022AY 2012-13

Section 147Section 148Section 194A

through the P&L A/C, it is observed that total receipts shown in the P&LA/c of Rs.5,79,039/- only and claimed credit for TDS. The assessee has under stated the receipts as reflected in the 26AS report. 2 M/s. Rajdeep Marketing Pvt. Ltd. 3. In the case

Dhl Logistics Pvt.Ltd, Mumbai vs. Addl/Jt/Dy/ACIT/ITO/NFAC, Delhi

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

ITA 553/MUM/2022[2017-18]Status: DisposedITAT Mumbai31 Oct 2022AY 2017-18

Bench: Kuldip Singh () & Shri Om Prakash Kant ()

Section 234Section 234BSection 271ASection 27oSection 920

Rs.1,76,71,200/-. 13 ITA 553/Mum/2022 17. Before us, the Ld.Counsel of the assessee submitted that in the return of income, credit for TDS of Rs.36,22,36,938/- was claimed; however, a short credit of Rs.1,76,72,200/- was granted by the Assessing Officer and, therefore, matter

ACIT CC 3(4) Cen RG 3, Mumbai vs. Patel Engineering Ltd, Mumbai

In the result, cross objection filed by the assessee is partly allowed

ITA 2758/MUM/2017[2009-10]Status: DisposedITAT Mumbai31 Oct 2022AY 2009-10

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 14ASection 199(2)Section 801A(4)Section 80I

enterprises" 2. "On the facts and in the circumstances of the case and in law, the CIT(A) erred in allowing that the credit of TDS be allowed to the assessee in contravention to section 199(2) of the IT Act, 1961, since the advances pertaining thereto are not credited ... advances/loans received, the payer/principal uniformly deducts tax at source u/s 194C of the Act. The AO has, citing section 199, has disallowed credit of TDS as the advances pertaining thereto are not credited to the profit and loss account during the year. The CIT(A) concurred with the view

ACIT CC 3(4) Cen RG 3, Mumbai vs. Patel Engineering Ltd, Mumbai

In the result, cross objection filed by the assessee is partly allowed

ITA 2757/MUM/2017[2008-09]Status: DisposedITAT Mumbai31 Oct 2022AY 2008-09

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 14ASection 199(2)Section 801A(4)Section 80I

Bsr Infratech India Limited, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-2(1), Bangalore

In the result, the appeal of the assessee is partly allowed

ITA 697/BANG/2022[2017-18]Status: DisposedITAT Bangalore27 Oct 2022AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2017-18

For Appellant: Shri Madhusudhan, A.RFor Respondent: Shri Praveen Karanth, D.R

Section 199Section 234ASection 270ASection 43Section 43C

assessee. The AO also noted that the assessee claimed TDS which was deducted on the gross bill and the assessee had claimed credit for TDS including the TDS of retention money during the year. Therefore, according to AO, the retention money has to be included as income accrued in this ... reflected in Form No.26AS. 8. The Ld. A.R. submitted that it is a well settled principle that a tax payer should be given credit for TDS in the year in which the corresponding income is offered to tax. The payer/ deductor shall deduct tax at source at the time

Bulldog Media and Entertainment Private Limited, Mumbai vs. Commissioner of Income Tax (Appeals ), Mumbai

In the result, appeal filed by the assessee is allowed

ITA 405/MUM/2022[2018-2019]Status: DisposedITAT Mumbai20 Oct 2022AY 2018-2019

Bench: Shri Aby T Varkey & Shri Gagan Goyalbulldog Media & Entertainment Pvt. Ltd. Plot No. C-38-C-39, G-Block, Parinee Crescenzo Building, Behind Mumbai Cricket Association, Bandra Kurla Complex, Mumbai-400051. Pan: Aadcb2393K ...... Appellant Vs. Cit (Appeals), National Faceless Appeal Centre, C.R. Building, Ip Estate, New Delhi-110002 ..... Respondent Appellant By : None Respondent By : Sh. Chetan M. Kacha, Sr.Dr Date Of Hearing : 27/07/2022 Date Of Pronouncement : 20/10/2022 Order Per Gagan Goyal, A.M: This Appeal By The Assessee Is Directed Against The Order Of National Faceless Appeal Centre, Delhi [Hereinafter Referred To As [‘Nfac’] Dated 02.11.2021 Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As [‘The Act’] For The Assessment Year (Ay) 2018-19. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: NoneFor Respondent: Sh. Chetan M. Kacha, Sr.DR

Section 143Section 143(1)(A)Section 154Section 155Section 199Section 203Section 250

relied in the case of Escorts Ltd. Vs. DCIT (2007) 15 SOT 368 (Delhi ITAT) held as under: "6. The scheme for giving credit for TDS was sought to be modified through clauses 56 and 59 of the Finance Bill, 2002 and the same have also been explained ... certificate is produced before the Assessing Officer within two years from the end of the assessment year in which such income is assessable, credit of TDS shall be given to the assessee on production of such certificate. Nothing contained in the proposed sub-section shall apply unless the income from

M/S Pkf Sridhar & Santhanam LLP, Chennai vs. DCIT, Chennai

In the result, the appeals filed by the assessee for assessment years 2018-19 & 2019-20 are allowed for statistical purposes

ITA 670/CHNY/2022[2019-2020]Status: DisposedITAT Chennai19 Oct 2022AY 2019-2020

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 669 & 670/Chny/2022 िनधा"रण वष" / Assessment Years: 2018-19 & 2019-2020

For Appellant: Shri. D. Palanevel, AdvocateFor Respondent: Shri. P. Sajit Kumar, JCIT

Commissioner of Income Tax (Appeals) is opposed to law and contrary to the facts and circumstances of the case. 2. Short Credit of TDS - Rs.78,31,008/-: 2.1 The Commissioner of Income Tax (Appeals), NFAC grossly erred in upholding the action of the Assessing Officer in not giving credit ... assessment year 2018-19 and Rs. 5,84,96,540/- for assessment year 2019-20. The AO had also given credit for TDS for assessment year 2018-19 at Rs. 2,42,96,750/- as against the claim of the assessee at Rs. 3,21,27,758/-. Similarly, for assessment