“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

Samay Safe Lockers Private Limited, Mumbai vs. ITO 2(3)(2), Mumbai

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

ITA 1671/MUM/2019[2013-14]Status: DisposedITAT Mumbai25 Mar 2022AY 2013-14

Bench: Shri M Balaganesh & Shri Pavan Kumar Gadaledcit 6(2)(1), Vs. Credit Analysis & R.No. 563, Aayakar Research Ltd., Bhavan, Mk Road, 5Th Floor, Rbc Churchgate, Mahindra Towers, Mumbai – 400020. Road No.13, Worli Mumbai-400018. Pan/Gir No. : Aaacc4587F Appellant .. Respondent Appellant By : Shri Pratap Singh, Dr Respondent By : Ms. Priyank Jain, Ar Date Of Hearing 31.05.2021 Date Of Pronouncement 14.06.2021 आदेश / O R D E R Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Revenue Against The Order Of The Commissioner Of Income Tax (Appeals) -12 Mumbai, Passed U/S. 143(3) & 250 Of The Income Tax Act, 1961. The Revenue Has Raised The Following Grounds Of Appeal:

For Appellant: Shri Pratap Singh, DRFor Respondent: Ms. Priyank Jain, AR

Section 143(1)Section 143(2)Section 143(3)Section 37(1)

revenue recognition accounting with respect of surveillance fee is bonafide and directed the A.O. to delete the addition and also allow the credit of TDS certificate in the year when such income is taxed as per Rule 37BA(3)(i) of IT Rules and granted relief in other grounds ... revenue reorganization policies is for a bonafide reason. The appellant also argued that provisions of Rule 37BA(3)(i) specifies for claiming credit of TDS and does not apply to accounting of income and merely because the appellant has claimed credit for TDS of the said

Biocon Ltd, Bangalore vs. Deputy Commissioner of Income Tax, Ltu, Bangalore

ITA 1248/BANG/2014[2012-13]Status: DisposedITAT Bangalore21 Mar 2022AY 2012-13

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranassessment Year : 2012-13

For Appellant: Shri Padamchand Khincha, A.RFor Respondent: Shri Sumer Singh Meena, D.R

Section 190Section 201Section 201(1)Section 40

possible to deduct TDS without knowing identity of the payee. In other cases, the payees may not be able to claim credit for TDS amount, since they are not aware of the provision for expenses created at assessee’s end. This is for the reason that the payees/vendors would

Karnataka State Electronics Development Corporation Limited, Bengaluru vs. Deputy Commissioner of Income Tax, CPC, Bangalore

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

ITA 599/BANG/2021[2018-19]Status: DisposedITAT Bangalore11 Mar 2022AY 2018-19

Bench: Shri N.V. Vasudevan & Shri B. R. Baskaranassessment Year :2018-19 M/S. Karnataka State Electronics Vs. The Deputy Commissioner Of Development Corporation Ltd., Income Tax, 2Nd Floor, Ttmc “A” Block, Cpc, Bengaluru. Bmtc, Shanthinagar, K. H. Road, Bengaluru–560 027. Pan : Aabck 6661 P Appellant Respondent Assessee By : Shri. Raghavendra R Chakravarthy, Ca Revenue By : Shri. Sankar Ganesh K, Jcit(Dr)(Itat), Bengaluru. Date Of Hearing : 09.03.2022 Date Of Pronouncement : 11.03.2022 O R D E R

For Appellant: Shri. Raghavendra R Chakravarthy, CAFor Respondent: Shri. Sankar Ganesh K, JCIT(DR)(ITAT), Bengaluru

Section 10Section 139(1)Section 143(1)Section 36Section 36(1)(va)Section 43B

Government of Karnataka as taxable income though such receipt of award is exempt u/s 10(17A). 6. The AO has not given the credit of TDS deducted by the Karnataka High Court of Rs. 96,654/-. AO should be directed to give credit of TDS as per form ... present case and therefore we confirm the order of the CIT(A). 15. As far as ground No.6 is concerned, the credit for TDS was denied because of the mismatch in Form 26AS. From a perusal of ground No.6, it appears that the assessee has a physical TDS certificate

M/S Te Connectivity India Private Limited, Bangalore vs. Assistant Commissioner of Income Tax Circle-2 Ltpu, Bangalore

In the result, the appeal by the assessee is treated as partly allowed for 37

ITA 3373/BANG/2018[2014-15]Status: DisposedITAT Bangalore25 Feb 2022AY 2014-15

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranit(Tp)A No.3373/Bang/2018 Assessment Year : 2014-15 M/S. Te Connectivity India Private Limited, Vs. Acit, Te Park, 22B, Doddenakundi Corporation, 2Nd Circle - 2, Large Taxpayer Unit, Phase, Industrial Area, Whitefield Road, Bengaluru. Bengaluru – 560 048. Pan : Aabct 7374 C Assessee Respondent Assessee By : Shri. Sriram Seshadri, Advocate Revenue By : Shri. Sumer Singh Meena, Cit(Dr)(Itat), Bengaluru Date Of Hearing : 22.02.2022 Date Of Pronouncement : 25.02.2022 O R D E R Per N V Vasudevan

For Appellant: Shri. Sriram Seshadri, AdvocateFor Respondent: Shri. Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 144C

that it would be just and appropriate to direct the AO to consider the claim of the assessee as made above and allow credit for TDS in accordance with law, after affording assessee opportunity of being heard. In the result, the appeal by the assessee is treated as partly allowed

M/S Ul India Pvt. Ltd., Bangalore vs. DCIT, Bangalore

In the result, appeal of the Assessee is partly allowed

ITA 655/BANG/2016[2011-12]Status: DisposedITAT Bangalore24 Feb 2022AY 2011-12

Bench: Shri N.V. Vasudevan & Shri B. R. Baskaranit(Tp)A No.574/Bang/2015 Assessment Year : 2010-11 M/S. Ul India Pvt. Ltd., Vs. The Deputy Commissioner Of Income Tax, Kalyani Platina – Block I, 3Rd Floor, 24, Epip Circle -7(1)(1), Zone, Phase – 2Nd, Whitefield, Bengaluru. Bengaluru – 560 066. Pan : Aaacu 2468 F Appellant Respondent It(Tp)A No.378/Bang/2015 Assessment Year : 2010-11 The Deputy Commissioner Of Income Tax, Vs. M/S. Ul India Pvt. Ltd., Circle -7(1)(1), Bengaluru – 560 066. Bengaluru. Pan : Aaacu 2468 F Appellant Respondent C.O.No.127/Bang/2015 (In It(Tp)A No.378/Bang/2015) Assessment Year : 2010-11 The Deputy Commissioner Of Income Tax, Vs. M/S. Ul India Pvt. Ltd., Circle -7(1)(1), Bengaluru – 560 066. Bengaluru. Pan : Aaacu 2468 F Cross Objector Respondent It(Tp)A No.655/Bang/2016 Assessment Year : 2011-12 M/S. Ul India Pvt. Ltd., Vs. The Deputy Commissioner Of Income Tax, Bengaluru – 560 066. Circle -7(1)(1), Pan : Aaacu 2468 F Bengaluru. Appellant Respondent

For Appellant: Shri. K. R. Vasudevan, AdvocateFor Respondent: Shri. Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 144C(13)Section 92Section 92C

same has been offered to tax. B. Denial of TDS credit 1. The learned AO has erred In denying TDS credit contending that credit for TDS cannot be claimed on unearned income and advances received. 2. The learned AO ought to have placed reliance on various judicial precedents wherein ... held that credit for TDS has to be provided to the assessee irrespective of the year to which the income relates. IT(TP)A Nos.574, 378/Bang/2015 655/Bang/2016 C.O. No.127/Bang/2015 Page 8 of 61 3. Notwithstanding the above, the learned AO ought not to have disallowed the TDS credit in respect

Ul India Private Limited, Bangalore vs. DCIT, Bangalore

In the result, appeal of the Assessee is partly allowed

ITA 574/BANG/2015[2010-11]Status: DisposedITAT Bangalore24 Feb 2022AY 2010-11

For Appellant: Shri. K. R. Vasudevan, AdvocateFor Respondent: Shri. Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 144C(13)Section 92Section 92C

DCIT, Bangalore vs. M/S U.L. India Pvt. Ltd., Bangalore

In the result, appeal of the Assessee is partly allowed

ITA 378/BANG/2015[2010-11]Status: DisposedITAT Bangalore24 Feb 2022AY 2010-11

For Appellant: Shri. K. R. Vasudevan, AdvocateFor Respondent: Shri. Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 144C(13)Section 92Section 92C

Ibm India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

In the result, appeal by the assessee stands allowed as indicated hereinabove

ITA 289/BANG/2021[2015-16]Status: DisposedITAT Bangalore14 Feb 2022AY 2015-16

Bench: Shri. B.R. Baskaran & Smt. Beena Pillaiit(Tp)A No. 289/Bang/2021 Assessment Year : 2015-16 M/S. Ibm India Pvt. Ltd., The Deputy No. 12, Subramanya Commissioner Of Arcade, Income-Tax, Bannerghatta Road, Circle 3 (1)(1), Bangalore – 560 029. Vs. Bangalore. Pan: Aaaci4403L Appellant Respondent Assessee By : Shri Ajay Roti, Ca Revenue By : Shri Pradeep Kumar, Cit Dr Date Of Hearing : 12-01-2022 Date Of Pronouncement : 14-02-2022 Order Per Beena Pillaipresent Appeal By The Assessee Has Been Filed By Assessee Against The Final Assessment Order Dated 30.04.2021 U/S. 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Act Passed By The National Faceless Assessment Centre, Delhi Relating To Assessment Year 2015-16 On Following Grounds Of Appeal: “The Grounds Stated Hereunder Are Independent Of & Without Prejudice To One Another. The Appellant Submits As Under: 1. Assessment Order Bad In Law 1.1. At The Outset, M/S Ibm India Private Limited (Hereinafter Referred To As 'The Appellant' Or 'The Company') Prays That The Order Dated April 30. 2021

For Appellant: Shri Ajay Roti, CAFor Respondent: Shri Pradeep Kumar, CIT DR

Section 10ASection 143(3)Section 144BSection 144C(13)

granted to assessee and Ground No. 15 is on non granting of credit for SA Tax. We direct the Ld.AO to grant the credit for TDS deducted and SA Tax on verification in accordance with law. Accordingly, this Grounds 13 & 15 raised by assessee stands allowed for statistical purposes

Hapag-Lloyd Ag, Mumbai vs. Dy CIT (International Taxation)-2(2)(2), Mumbai

The appeal of the assessee is allowed with above directions

ITA 972/MUM/2021[2017-18]Status: DisposedITAT Mumbai31 Jan 2022AY 2017-18

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Hapag-Lloyd Ag The Dy. Commissioner Of C/O Hapag-Lloyd India Pvt. Income-Tax (International Ltd. Taxation), Range -2(2)(2), Room No. 1606, 16 Th Floor, 403 & 404, Satellite Gazebo, Vs. A Wing, 4Th Floor, Guru Air India Building, Nariman Hargoindji Marg, Andheri Point, Mumbai-400 021 (East), Mumbai-400 093 Appellant .. Respondent Pan No. Aacfe7262L Assessee By : Shri Nishant Thakkar Ms. Jasmin Amalsadvala, Advocates, Revenue By : Shri Milind Chavan, Dr

For Appellant: Shri Nishant ThakkarFor Respondent: Shri Milind Chavan, DR

Section 143Section 234Section 270Section 270ASection 44BSection 90(2)

Under:- “16. We find that the assessee has also assailed before asked the failure on the part of the AO grant credit for TDS of ₹ 6,006,811/– for the reason, that the same was wrongly deposited in the PAN number of the agent of the assessee. It was submitted

M/S. Centum Electronics Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle - 2(1)(1), Bangalore

In the result appeal filed by assessee stands allowed on the legal issue raised

ITA 946/BANG/2019[2008-09]Status: DisposedITAT Bangalore31 Jan 2022AY 2008-09

Bench: Shri B. R. Baskaran & Smt. Beena Pillaiassessment Year: 2008-09 M/S. Centum Electronics Ltd. #44, Ground Floor, Deputy Commissioner Of Khb Industrial Area Vs. Income-Tax Yelahanka New Town Circle-2(1)(1) Bengaluru 560 106 Bengaluru Pan No : Aakcs7429L Appellant Respondent Appellant By : Shri S. Ramasubrammaniam, A.R. Respondent By : Shri Srinath Sadanala, D.R. Date Of Hearing : 13.12.2021 Date Of Pronouncement : 31.01.2022 O R D E R Per Beena Pillai: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A) Bengaluru-2 Dated 28.2.2019 For The Assessment Year 2008-09. The Grounds Of Appeal Raised By The Assessee In This Appeal Are Reproduced As Follows:- That The Order Of The Learned Commissioner Of Income-Tax (Appeals) In 1. So Far It Is Prejudicial To The Interests Of The Appellant Is Bad & Erroneous In Law & Against The Facts & Circumstances Of The Case. That The Learned Commissioner Of Income Tax (Appeals) Erred In Law & 2. On Facts In Justifying The Action Of The Assessing Officer In Passing An Order Against M/S. Solectron Ems India Ltd Even Though The Said Entity Does Not Exist On The Date Of The Passing The Order. That The Learned Commissioner Of Income Tax (Appeals) Erred In Law & 3. On Facts In Upholding The Action Of The Assessing Officer In Passing An Assessment Order Against A Non-Existing Person. 4. That The Order U/S 147 Is Without Jurisdiction.

For Appellant: Shri S. Ramasubrammaniam, A.RFor Respondent: Shri Srinath Sadanala, D.R

Section 10BSection 147Section 40

reduced from export turnover. 15. That the learned Commissioner of Income Tax (Appeals) ought to have considered the claim for extra depreciation, extra credit for TDS and wrong disallowance u/s 40(a)(ia) of the Act. ITA No.946 /Bang/2019 M/s. Centum Electronics Ltd., Bangalore Page

Nagravision Sa, Gurgaon vs. DCIT Circle-2(2)(2) Internatioanl Taxation, New Delhi

In the result the Appeal filed by the Appellant is partly allowed for statistical purposes

ITA 140/DEL/2021[2017-18]Status: DisposedITAT Delhi31 Jan 2022AY 2017-18

Bench: Sh. R.K. Panda & Sh. N. K. Choudhry(Through Video Conferencing) Assessment Year: 2017-18 M/S. Nagravision S.A. Vs Dcit C/O. Ernst & Young Llp, Circle-2(2)(2), Golf View Corporate International Taxation, Tower,Tower B, Sector 42, New Delhi Golf Course Road, Gurugram Pan : Aadcn6048B (Appellant) (Respondent) Appellant By Smt. Ananya Kapoor, Adv. Respondent By Ms. Naina Soin Kapil, Cit Date Of Hearing: 06/01/2022 Date Of Pronouncement: 31/01/2022 Order Per N. K. Choudhry, Jm:

Section 143(3)Section 144CSection 154Section 270Section 270ASection 9

assessing the income of Rs. 55,72,38,772/- u/s. 154 r.w.s. 143(3) of the Act., however the Ld. DCIT restricted the credit of TDS at Rs. 5,57,23,879 instead of Rs. 5,66,27,192/- previously allowed to the Appellant vide assessment order dated 28 December ... credit for Taxes Deducted at Source (‘TDS’) and initiation of penalty proceedings 5. That the Ld. AO has erred in restricting the credit for TDS to Rs. 5,52,23,879 as per the rectification order dated 11 January 2021 passed u/s 154 of the Act r.w.s

Tata Realty and Infrastructure Ltd, Mumbai vs. Ast CIT 2(3)(1), Mumbai

ITA 763/MUM/2020[2015-16]Status: DisposedITAT Mumbai28 Jan 2022AY 2015-16

For Appellant: Aarti VissanjiFor Respondent: Sanjeev Kashyap

Section 115JSection 143(2)Section 143(3)

view that even if it is considered that the TDS was deducted on capital receipt the credit for TDS should be given in F.Y. 2013-14 when the debit notes were raised and not in the F.Y. 2014-15. Therefore, claim of TDS amount of Rs.3.55 crores was disallowed

Jt CIT(OSD) 2(3)(1), Mumbai vs. M/S Tata Realty and Infrastructure Ltd., Mumbai

ITA 730/MUM/2020[2015-16]Status: DisposedITAT Mumbai28 Jan 2022AY 2015-16

For Appellant: Aarti VissanjiFor Respondent: Sanjeev Kashyap

Section 115JSection 143(2)Section 143(3)

Gemolagical Institute of America Inc., Mumbai vs. The ACIT (International Taxation) Circle-2(3)(2), Mumbai

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

ITA 975/MUM/2021[2017-18]Status: DisposedITAT Mumbai17 Jan 2022AY 2017-18

Section 143(3)Section 144C(5)

20/05/2021 which is pending disposal. The ld. AO is hereby directed to dispose of the said rectification petition and grant credit for TDS in accordance with law at the earliest. Accordingly, the ground No.7 is allowed for statistical purposes. 8. The ground No.8 raised by the assessee is with regard

M/S.Nds Limited, Bangalore vs. Asst. Commissioner of Income Tax, Bangalore

In the result, the appeal filed by assessee stands allowed

ITA 364/BANG/2017[2007-2008]Status: DisposedITAT Bangalore28 Dec 2021AY 2007-2008

Bench: Shri. B.R. Baskaran & Smt. Beena Pillaiit(It)A No. 364/Bang/2017 Assessment Year : 2007-08 M/S. Synamedia Ltd. [Formerly Known As ‘Nds Limited’], The Assistant C/O. M/S. Synamedia India Pvt. Commissioner Of Ltd., Income Tax, Block 9A & 9B, Pritech Park, International Survey No. 51-64/4, Taxation, Sarjapur Outer Ring Road, Vs. Circle – 1(2), Bellandur Village, Bangalore. Bangalore – 560 103. Pan: Aabcn2524L Appellant Respondent Assessee By : Shri Sharath Rao, Advocate : Shri Dilip, Standing Revenue By Counsel For Dept. Date Of Hearing : 16-12-2021 Date Of Pronouncement : 28-12-2021

For Appellant: Shri

Section 143(3)Section 147Section 234B

case (supra) as under. “42. Ground No.5 raised by the assessee in its appeal is with regard to non-grant of credit for TDS. In our view, it would be just and appropriate to direct the AO to consider the calim of the assessee and allow credit in accordance with

Uberoi Sood & Kapoor, New Delhi vs. ACIT, Circle- 63(1), New Delhi

In the result, appeal of the Assessee is allowed

ITA 2642/DEL/2018[2014-15]Status: DisposedITAT Delhi24 Dec 2021AY 2014-15

Bench: Shri R.K. Panda & Shri Narendra Kumar Choudhary

For Appellant: Shri Sanjay Sood, AdvocateFor Respondent: Ms. Sangeeta Yadav, Sr. DR

Section 198Section 199

directed to give credit of the proportionate TDS of Rs.1,00,081/- in the year under consideration as well as to give credit of TDS as per provisions of section 199 to be read with rule 37BA of the Income Tax Act provided the appellant has reflected the income ... give credit of the proportionate TDS of Rs.1,00,081/- in the year under consideration as well as to give credit of TDS as per the provisions of Section 199 to be read with Rule 37BA of the I.T. Act, 1961. It is the submission of the Learned Counsel

San Disk India Device Design Centre Pvt. Ltd., Bangalore vs. ITO, Bangalore

In the result, appeal of the Revenue is dismissed and appeal of the assessee is partly allowed

ITA 543/BANG/2015[2010-11]Status: DisposedITAT Bangalore15 Dec 2021AY 2010-11

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Smt. Tanmayee Rajkumar, AdvocateFor Respondent: Shri. Sunil Kumar Singh, CIT(DR)(ITAT), Bengaluru

Section 10ASection 143(3)Section 154Section 92C

credit entitlement under section 115JAA of the Act. 12. Non-grant of TDS credit The AO has erred in not granting the credit for TDS of Rs. 7,546. 13. Short-grant of advance tax The AO had erred in restricting credit for advance

DCIT, Bangalore vs. M/S Sandisk India Device Design Centre Private Limited, Bangalore

In the result, appeal of the Revenue is dismissed and appeal of the assessee is partly allowed

ITA 341/BANG/2015[2010-11]Status: DisposedITAT Bangalore15 Dec 2021AY 2010-11

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Smt. Tanmayee Rajkumar, AdvocateFor Respondent: Shri. Sunil Kumar Singh, CIT(DR)(ITAT), Bengaluru

Section 10ASection 143(3)Section 154Section 92C

Srf Limited, New Delhi vs. ACIT, Circle- 1, Ltu, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 6620/DEL/2018[2014-15]Status: DisposedITAT Delhi13 Dec 2021AY 2014-15

Bench: Sh. Anil Chaturvedi & Shri Kuldip Singh(Through Video Conferencing) Srf Limited Vs. Acit The Galleria, Dlf Mayur Circle – 1, Vihar, Unit No.236 & 237, Ltu 2Nd Floor, Mayur Place, New Delhi Noida Link Road, Mayur Vihar, Phase-I, Extension, Delhi-110 091 Pan : Aaacs 0206 P (Appellant) (Respondent) Assessee By Shri Pradeep Dinodia, C.A. Revenue By Ms. Meera Srivastava, Cit-D.R. Date Of Hearing: 16.09.2021 Date Of Pronouncement: 13.12.2021 Order Per Anil Chaturvedi, Am :

Section 115JSection 143(2)Section 143(3)Section 144C(5)Section 92C

lower authorities. 37 62. We have heard the rival submissions and perused the material available on record. Before us, assessee is seeking the credit for TDS amounting to Rs.2,70,000/- deducted on sale of immovable property and the claim of self assessment amounting to Rs.47,61,334/- which

Turner Broadcasting System Asia Pacific Inc., New Delhi vs. DCIT (International Taxation), Circle-3(1)(1), New Delhi

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

ITA 4325/DEL/2018[2014-15]Status: DisposedITAT Delhi08 Dec 2021AY 2014-15

Bench: Sh. N. K. Billaiya & Sh. C. N. Prasad(Through Video Conferencing) Assessment Year: 2014-15 Turner Broadcasting Dcit (International System Asia Pacific Inc. Vs Taxation), Circle – 3 (1) (1) C/O Pricewaterhouse New Delhi Coopers Pvt. Ltd. Sucheta 1St Bhawan, Gate No.2, Floor, 11-A, Vishnu Digamber Marg, New Delhi-110002 Pan No.Aabct6254F (Appellant) (Respondent)

Section 143(3)Section 144Section 144C(13)Section 271Section 9

given full credit of tax deducted at source. We accordingly direct the AO to consider the claim of the credit of TDS and if found correct, allow the same to the assessee. 12. Ground No.6 is treated as allowed for statistical purpose. 13. Ground No.7 relates to non allowance ... Parragon Publishing India Pvt. Ltd. during the year on which taxes were withheld at source. When the assessee claimed the credit of TDS the same was denied by the AO and the DRP by holding that since the assessee has not offered the revenue as its income during the year