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“tax deducted at source”

Chapter XVII - Collection & Recovery (TDS)Chapter XVII-BChapter XVII-B / Rule 26B / Rule 37BA(2)2,249 judgments

The decision most relied on for tax deducted at source is GE India Technology Centre Pvt. Ltd. v. CIT (327 ITR 456), cited in 663 judgments on BharatTax.

Leading authorities on tax deducted at source

GE India Technology Centre Pvt. Ltd. v. CIT
327 ITR 456 · 2010 · Supreme Court
663
citing judgments

Tax must be deducted at source from payments made to a non-resident under Section 195 only if such payment is chargeable to tax in India. The Assessing Officer bears the onus to establish that the payments made are indeed chargeable to tax under the Income Tax Act.

Gajanan Constructions v. DCIT
74 Taxmann.com 6 · 2016 · ITAT
465
citing judgments

Late fees under section 234E can only be levied prospectively from June 1, 2015. Levying late fees for periods prior to this date is not permissible.

CIT v. Samsung Electronics Ltd.
345 ITR 494 · 2012 · High Court
461
citing judgments

Payments by Indian residents to non-resident foreign software suppliers for software are considered royalty, constituting income deemed to accrue in India under section 9(1)(v), thereby requiring tax deduction at source under section 195.

CIT v. Ansal Land Mark Township (P) Ltd.
377 ITR 635 · 2015 · High Court
369
citing judgments

The second proviso to Section 40(a)(ia), introduced by the Finance Act, 2012, is curative and applies retrospectively from April 1, 2005. Consequently, if the recipient of a payment has filed their return and paid taxes on the amount from which tax was not deducted at source, the payer's expenditure cannot be disallowed under Section 40(a)(ia).

Transmission Corporation of Andhra Pradesh v. CIT
239 ITR 587 · 1999 · Supreme Court
243
citing judgments

The Supreme Court lays down principles for deducting tax at source (TDS) under Section 195 on payments to non-residents, including aspects of income deemed taxable in India and the application of Double Taxation Avoidance Agreements (DTAAs) under Section 90.

PCIT v. Peroorkada Service Co-op. Bank Ltd.
442 ITR 141 · 2022 · High Court
208
citing judgments

Interest income earned by a co-operative society from deposits with other co-operative banks, such as district or state co-operative banks, is eligible for deduction under Section 80P(2)(d) of the Income-tax Act, as it is considered income from other sources.

DIT v. GE Packaged Power Inc.
373 ITR 65 · 2015 · High Court
199
citing judgments

Interest under section 234B for default in payment of advance tax is not leviable when the entire income is subject to tax deduction at source under section 195, as no advance tax liability arises for the assessee in such circumstances.

CIT v. Ansal Landmark Township (P.) Ltd.
61 Taxmann.com 45 · 2015 · High Court
177
citing judgments

Disallowance under section 40(a)(ia) cannot be made when the assessee has deducted tax at a lesser rate, as opposed to no deduction. The second proviso to section 40(a)(ia) is applicable retrospectively, mitigating disallowance where tax is deposited by the recipient.

Judgments citing tax deducted at source

Deputy Commissioner of Income Tax, Circle 1(1), Jabalpur vs. Shri Indrabhan Singh Rathore, Narsinghpur

In the result, appeal filed by the Revenue is dismissed

ITA 234/JAB/2018[2015-16]Status: HeardITAT Jabalpur08 Jan 2025AY 2015-16

Bench: Sh. Kul Bharat & Sh. Nikhil Choudhary

For Appellant: Shri. Aok Bhura, DRFor Respondent: Shri Sapan Usrethe, Adv
Section 143(3)Section 250Section 68

Payments had been made to them on which tax were being deducted at source. Details of PAN, payments made to the petty contractors, tax deducted at source and details of security deposit retained, alongwith their affidavits had been filed. The learned CIT(A) held that it was common knowledge that

Income Tax Officer (TDS), Cuttack vs. Maa Tarini Transport Private Limited, Barbil, Keonjhar

In the result, appeals of the revenue stand dismissed

ITA 455/CTK/2024[2014-15]Status: HeardITAT Cuttack07 Jan 2025AY 2014-15

Bench: Before Shri George Mathanmember & Manish Agarwal Manish Agarwalita Nos.454 & 455/Ctk/2024 Assessment Year : 2014-15 Income Tax Officer (Tds), Income Tax Officer (Tds), Vs. Maa Tarini Transport Pvt Maa Tarini Transport Pvt Cuttack Ltd., Ltd., Bhadrasahi, Bhadrasahi, Barbil, Barbil, Keonjhar Pan/Gir No.Aafcm 0416 L No.Aafcm 0416 L (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : None Revenue By : Shri S.C.Mohanty, Sr Dr : Shri S.C.Mohanty, Sr Dr Date Of Hearing : 07/01/20 2025 Date Of Pronouncement : 07/01/20 025 O R D E R Per Bench These Two These Two Appeals Filed By The Revenue Against The Against The Separate Orders Of The Ld Cit(A), Nfac, Delhi Dated Of The Ld Cit(A), Nfac, Delhi Dated 10.9.2024 In Appeal No.Cit(A),Cuttack/10412/2018 Cit(A),Cuttack/10412/2018-19 & Cit(A),Cuttack/10413/2018 19 & Cit(A),Cuttack/10413/2018-19 For The Assessment Year Essment Year 2014-15 Deleting The Levy Of Fees U/S.234E Of The Act. Deleting The Levy Of Fees U/S.234E Of The Act.

For Appellant: NoneFor Respondent: Shri S.C.Mohanty, Sr DR
Section 200(3)Section 200ASection 234E

enabling provision in section 200A of the Act for making adjustment in respect of the statement filed by the appellant with regard to tax deducted at source by levying fee under P a g e 2 | 4 ITA Nos.454 & 455/CTK/2024 Assessment Year : 2014-15 section 234E. Thus, while processing statement

Income Tax Officer, Cuttack vs. Maa Tarini Transport Private Limited, Barbil Koenjhar

In the result, appeals of the revenue stand dismissed

ITA 454/CTK/2024[2014-15]Status: HeardITAT Cuttack07 Jan 2025AY 2014-15

Bench: Before Shri George Mathanmember & Manish Agarwal Manish Agarwalita Nos.454 & 455/Ctk/2024 Assessment Year : 2014-15 Income Tax Officer (Tds), Income Tax Officer (Tds), Vs. Maa Tarini Transport Pvt Maa Tarini Transport Pvt Cuttack Ltd., Ltd., Bhadrasahi, Bhadrasahi, Barbil, Barbil, Keonjhar Pan/Gir No.Aafcm 0416 L No.Aafcm 0416 L (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : None Revenue By : Shri S.C.Mohanty, Sr Dr : Shri S.C.Mohanty, Sr Dr Date Of Hearing : 07/01/20 2025 Date Of Pronouncement : 07/01/20 025 O R D E R Per Bench These Two These Two Appeals Filed By The Revenue Against The Against The Separate Orders Of The Ld Cit(A), Nfac, Delhi Dated Of The Ld Cit(A), Nfac, Delhi Dated 10.9.2024 In Appeal No.Cit(A),Cuttack/10412/2018 Cit(A),Cuttack/10412/2018-19 & Cit(A),Cuttack/10413/2018 19 & Cit(A),Cuttack/10413/2018-19 For The Assessment Year Essment Year 2014-15 Deleting The Levy Of Fees U/S.234E Of The Act. Deleting The Levy Of Fees U/S.234E Of The Act.

For Appellant: NoneFor Respondent: Shri S.C.Mohanty, Sr DR
Section 200(3)Section 200ASection 234E

enabling provision in section 200A of the Act for making adjustment in respect of the statement filed by the appellant with regard to tax deducted at source by levying fee under P a g e 2 | 4 ITA Nos.454 & 455/CTK/2024 Assessment Year : 2014-15 section 234E. Thus, while processing statement

Krishan Dev Verma, Jaipur vs. ITO Ward - 1, Bhiwani

ITA 1147/DEL/2020[2014-15]Status: DisposedITAT Delhi06 Jan 2025AY 2014-15

Bench: Shri M. Balaganesh & Shri Anubhav Sharma

For Appellant: Shri Gaurav Jain, Advocate &For Respondent: Shri Dayainder Singh Sidhu, CIT-DR
Section 14Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 238Section 30(4)Section 31

Effective Date, all the dues under the provisions of Income Tax Act, 1961, including taxes, duty, penalties, interest, fines, cesses, unpaid tax deducted at source / tax collected at source, whether admitted or not, due or contingent, whether part of above claim of income tax authorities or not, asserted or unasserted

Assistant Commissioner of Income-Tax, Ahmedabad vs. Devraj Harshadray Patel, Ahmedabad

In the result, the appeal of the Department is dismissed

ITA 93/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad03 Jan 2025AY 2016-17

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri P. F. Jain, A.RFor Respondent: Shri B. P. Srivastava, Sr. D.R
Section 234Section 54BSection 68

assessee from Harishbhai Prahladbhai Patel (purchaser) through banking channels and an amount of Rs. 40,000/- was also withheld by the purchaser as Tax Deducted at Source (TDS). During the course of assessment, the Assessing Officer observed that against the aforesaid sale consideration of Rs. 40 lakhs, the assessee

The Sattavis Patidar Samaj Co.Op. Credit and Vividhlaxi Seva Society Ltd., Mehsana vs. The ITO, Ward-5, Patan

In the result, the appeal of the assessee is allowed

ITA 1477/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad03 Jan 2025AY 2017-18

Bench: Dr.Brr Kumarshri Siddhartha Nautiyal

For Appellant: NoneFor Respondent: Shri VK Mangla, Sr.DR
Section 194ASection 194A(3)(v)Section 263Section 80PSection 80P(2)(d)Section 80P(4)

amending section 194A(3)(v) is concerned, on perusal of section 194A (3), it appears that it provides for exemption from deducting Tax Deducted at Source from the income on interest other than interest on securities as the cooperative societies other than cooperative banks meaning thereby that the cooperative banks

Devraj Harshadrai Patel, Ahmedabad vs. The Dy.CIT., Circle-3(1)(1), Ahmedabad

In the result, the appeal of the Department is dismissed

ITA 1093/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad03 Jan 2025AY 2016-17

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri P. F. Jain, A.RFor Respondent: Shri B. P. Srivastava, Sr. D.R
Section 234Section 54BSection 68

assessee from Harishbhai Prahladbhai Patel (purchaser) through banking channels and an amount of Rs. 40,000/- was also withheld by the purchaser as Tax Deducted at Source (TDS). During the course of assessment, the Assessing Officer observed that against the aforesaid sale consideration of Rs. 40 lakhs, the assessee

Late Smt. Ramilaben Harshadrai Patel(Through L/H Devraj H.Patel), Ahmedabad vs. The Income Tax Officer, Ward-3(3)(2), Ahmedabad

In the result, the appeal of the Department is dismissed

ITA 1092/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad03 Jan 2025AY 2016-17

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri P. F. Jain, A.RFor Respondent: Shri B. P. Srivastava, Sr. D.R
Section 234Section 54BSection 68

assessee from Harishbhai Prahladbhai Patel (purchaser) through banking channels and an amount of Rs. 40,000/- was also withheld by the purchaser as Tax Deducted at Source (TDS). During the course of assessment, the Assessing Officer observed that against the aforesaid sale consideration of Rs. 40 lakhs, the assessee

ITO (It), Ward 2(1), Chennai vs. Rohitkumar Nemchand Piparia, Chennai

The appeal stands allowed for statistical purposes

ITA 1326/CHNY/2023[2008-09]Status: DisposedITAT Chennai31 Dec 2024AY 2008-09

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1326/Chny/2023 (िनधा*रण वष* / Assessment Year: 2008-09) Income Tax Officer Shri Rohitkumar Nemchand Piparia बनाम International Taxation Ward-2(1), #34 (Old #77), Meddox Street, / Vs. Chennai. Choolai, Chennai-600 112. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Akzpp-0661-M (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Assessee By : Shri T. Banusekar & Ms.Samyuktha Banusekar (Advocates) - Ld. Ars " थ"कीओरसे/Revenue By : Shri Nilay Baran Som (Cit) - Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 07-10-2024 घोषणाकीतारीख /Date Of Pronouncement : 31-12-2024 आदेश / O R D E R

For Appellant: Shri T. Banusekar & Ms.SamyukthaFor Respondent: Shri Nilay Baran Som (CIT) - Ld. DR
Section 143(3)Section 148Section 271(1)(c)

consideration of the Hon’ble ITAT: The intention behind the legislation of the provisions of the Act relating to TDS is "TDS or Tax Deducted at Source is income tax reduced from the money paid at the time of making specified payments by the persons making such payments" as advance ... income are liable to pay the relevant income tax on the amounts received under the relevant heads of income. The idea behind the Tax Deducted at Source provisions is only to make sure that income tax is deducted in advance from the payments being made to the payee and there

Msc Agency (India) Private Limited, Mumbai vs. ACIT, Cir-2(2)(2), Mumbai

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

ITA 929/MUM/2024[2018-19]Status: DisposedITAT Mumbai31 Dec 2024AY 2018-19

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri R. R. Makwana
Section 143(1)Section 143(2)Section 143(3)Section 250Section 270ASection 37(1)

NFAC erred in remanding the matter back to the learned AO to verify the claim of short-grant of credit of tax deducted at source amounting to Rs. 24,067. 4.9 The Appellant prays that the learned AO be directed to allow claim as per law. 4 Ground

Msc Agency (India) Private Limited, Mumbai vs. ACIT, Cir-2(2)(2), Mumbai

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

ITA 928/MUM/2024[2020-21]Status: DisposedITAT Mumbai31 Dec 2024AY 2020-21

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri R. R. Makwana
Section 143(1)Section 143(2)Section 143(3)Section 250Section 270ASection 37(1)

NFAC erred in remanding the matter back to the learned AO to verify the claim of short-grant of credit of tax deducted at source amounting to Rs. 24,067. 4.9 The Appellant prays that the learned AO be directed to allow claim as per law. 4 Ground

Msc Agency (India) Private Limited, Mumbai vs. ACIT, Cir-2(2)(2), Mumbai

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

ITA 927/MUM/2024[2017-18]Status: DisposedITAT Mumbai31 Dec 2024AY 2017-18

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri R. R. Makwana
Section 143(1)Section 143(2)Section 143(3)Section 250Section 270ASection 37(1)

NFAC erred in remanding the matter back to the learned AO to verify the claim of short-grant of credit of tax deducted at source amounting to Rs. 24,067. 4.9 The Appellant prays that the learned AO be directed to allow claim as per law. 4 Ground

Patel Engineering Limited, Mumbai vs. DCIT CC-3(4), Mumbai

In the result, appeals of the Revenue are dismissed, except for one ground no

ITA 2801/MUM/2024[2017-18]Status: DisposedITAT Mumbai31 Dec 2024AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 194ASection 201

assessee. The computation of income of the JV for the impugned year shows that the income reflected is Nil and no credit for tax deducted at source under the PAN of JV has been claimed, though Form 26AS of the JV does reflect such TDS. Further

Siyaram Exports India Pvt. Ltd., Jaipur vs. Deputy Commissioner of Income Tax, Jaipur

ITA 440/JPR/2018[2013-14]Status: DisposedITAT Jaipur30 Dec 2024AY 2013-14
For Appellant: Shri Rohan Sogani (C.A.)For Respondent: Shri Arvind Kumar (CIT-DR)
Section 142(1)Section 143(3)Section 144Section 153ASection 50C

2 ITA No. 331/JPR/2017 & 435 to 440/JPR/2018 ITA No. 467,468 & 352/JPR/2018 & 145 & 151/JPR/2024 आयकर अपील सं./ITA No. 145

Shri Satish Chandra Katta, Jaipur vs. Deputy Commissioner of Income Tax, Jaipur

In the result, Ground No. 3 is allowed for statistical purposes

ITA 437/JPR/2018[2011-12]Status: DisposedITAT Jaipur30 Dec 2024AY 2011-12
Section 142(1)Section 143(3)Section 144Section 153A

IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”A” JAIPUR BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI GAGAN GOYAL, AM आयकर

Mr. Rajeev Kumar Jain, Vivendi Building, Sarojini Road, Santacruz (W) vs. Circle 42(3)(1), Mumbai, Kautilya Bhavan

In the result, the appeal of the assessee bearing ITA No

ITA 5759/MUM/2024[2022-2023]Status: DisposedITAT Mumbai30 Dec 2024AY 2022-2023

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankarshri Rajeev Kumar Jain Vs Income-Tax Officer Circle 42(3)(1), 301, Vivendi Building, Mumbai, Kautilya Bhavan, Bkc Santacruz (West) S.O., Mumbai-400 051 Mumbai-400 054 Pan : Acopj0782E Applicant Respondent

For Appellant: ShriRahul KanojiaFor Respondent: Shri Balasaheb Nagwe (SR DR)
Section 143(1)Section 154Section 199Section 234Section 250Section 64Section 69

Accordingly, the delay for 219 days is condoned. 3. The appeal has been filed by the assessee challenging the denial of credit for Tax Deducted at Source (TDS) pertaining to his spouse. The assessee contends that since the income of the spouse, amounting to Rs. 46,76,589/-, was clubbed ... assessee's wife did not furnish declaration to the bank in terms of proviso to rule 37 BA(2), the amount of tax deducted at source, which is otherwise with the department, cannot be allowed to remain with it eternally without allowing any corresponding credit to the person

Eastern Cargo Carriers (India) Private Limited, Mumbai, Maharashtra, India vs. The Assessment Unit, Income Tax Department

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

ITA 4610/MUM/2023[2021-2022]Status: DisposedITAT Mumbai20 Dec 2024AY 2021-2022

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2021-22 M/S Eastern Cargo Carriers (India) The Assessment Unit, Income Tax Pvt. Ltd., Department, Vs. Unit No. 26, Adarsh Ind. Estates, Aaykar Bhavan, M.K. Road, Sahar Road, Andheri East, Mumbai-400020. Mumbai-400099. Pan No. Aaace 1520 E Appellant Respondent

For Appellant: Mr. Niraj Sheth a/wFor Respondent: Mr. Hemanshu Joshi, Sr. DR
Section 40A(2)(a)

Madras High Court in Chennai Properties & Investment Ltd. Properties & Investment Ltd. (supra) as under :- "21. As far as delay in remittance of tax deducted at source u/s. "21. As far as delay in remittance of tax deducted at source "21. As far as delay in remittance of tax deducted ... insofar as it relates to disallowance o of the CIT(A) insofar as it relates to disallowance o delayed remittance of tax deducted at source delayed remittance of tax deducted at source u/s. 201(1A) u/s. 201(1A) of the Act." 8. In view of this, we do not find

Shell Global Solutions International B.V, Mumbai vs. The ACIT, Intl. Taxn.-2, Ahmedabad

In the result, the appeal of the assessee is partly allowed, while the CO filed by the Revenue is dismissed

ITA 1783/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad18 Dec 2024AY 2015-16

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarwith Co No.20/Ahd/2022 Assessment Year : 2014-15 & 1783/Ahd/2019 Assessment Year : 2015-16 Shell Global Solutions International B.V.,, Acit, International C/O. Bsr Associates & Llp Vs Taxation-1 903, Commerce House V Ahmedabad. Nr.Vodafone House Prahaladnagar Corporation Road, Ahmedabad. Pan : Aaics 3589 H (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocate & Shri Parin Shah, Ar : Dr. Darsi Suman Ratnam, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 05/09/2024 & 06/12/2024 घोषणा क" तारीख /Date Of Pronouncement: 18/12/2024

Section 143(3)Section 144C

Court held that where assessee company availed diamond testing services for certification of diamond from U.S. company and claimed that payment was not tax deductible at source, assessee's case was protected under India-USA DTAA as mere rendering of services could not be roped into FTS since assessee company ... deleted. Ground no.5 is allowed. ITA No.2390/Ahd/2018 & 1783/Ahd/2019 with CO 32 55. Ground No.6 reads as under: “6. Short credit of Tax Deducted at Source ('IDS') - INR 10,69,502 The learned AO has erred on the facts and in circumstances of the case and in law in giving short

Shell Global Solutions International B.V, Mumbai vs. The ACIT, Intl. Taxn.-1, Ahmedabad

In the result, the appeal of the assessee is partly allowed, while the CO filed by the Revenue is dismissed

ITA 2390/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad18 Dec 2024AY 2014-15

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarwith Co No.20/Ahd/2022 Assessment Year : 2014-15 & 1783/Ahd/2019 Assessment Year : 2015-16 Shell Global Solutions International B.V.,, Acit, International C/O. Bsr Associates & Llp Vs Taxation-1 903, Commerce House V Ahmedabad. Nr.Vodafone House Prahaladnagar Corporation Road, Ahmedabad. Pan : Aaics 3589 H (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocate & Shri Parin Shah, Ar : Dr. Darsi Suman Ratnam, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 05/09/2024 & 06/12/2024 घोषणा क" तारीख /Date Of Pronouncement: 18/12/2024

Section 143(3)Section 144C

Court held that where assessee company availed diamond testing services for certification of diamond from U.S. company and claimed that payment was not tax deductible at source, assessee's case was protected under India-USA DTAA as mere rendering of services could not be roped into FTS since assessee company ... deleted. Ground no.5 is allowed. ITA No.2390/Ahd/2018 & 1783/Ahd/2019 with CO 32 55. Ground No.6 reads as under: “6. Short credit of Tax Deducted at Source ('IDS') - INR 10,69,502 The learned AO has erred on the facts and in circumstances of the case and in law in giving short

Nr Agrawal Co, Andheri West Mumbai vs. ITO, 16 (3) (1), Ayakar Bhavan Churchgate Mumbai

In the result, appeal of the assessee is partly allowed

ITA 4319/MUM/2024[2017 18]Status: DisposedITAT Mumbai18 Dec 2024

Bench: Ms. Kavitha Rajagopal & Shri Girish Agrawalassessment Year: 2017-18

For Appellant: Shri N. R. Agrawal, CAFor Respondent: Smt. Pravin Salunkhe, Sr. DR
Section 143(1)Section 154

forward of TDS and also that no TDS was carried forward. In this respect, reference was made to “schedule 15B1-TDS1: details of tax deducted at source from income (as per Form 16A issued by deductors)” forming part of the return filed by the assessee on 20.03.2020, pursuant to rectification ... which the head note reads as under: “TDS-Credit for TDS-System of IT Department is not allowing any credit of tax deducted at source (TDS) for the assessment year in question-According to Revenue the online credit of tax deducted at source (TDS) claims for these years