ORDER

PER RAVISH SOOD, JM:

The present appeal filed by the assessee company is directed against the order passed by the Addl/Joint Commissioner of Income Tax (Appeals)-1, Nashik, dated 05/08/2025, which in turn arises from the order passed by the Assessing Officer (for short, “AO”) under section 154 of the Income Tax Act, 1961 (for short, “the Act”), dated 17/10/2022 for the Assessment Year (AY) 2020-21. The assessee company has assailed the impugned order of the CIT(A) on the following grounds of appeal:

1. That on the facts and in the circumstances of the case and in law, the Learned CIT(A) erred in confirming the denial of TDS credit of 28,12,189/- pertaining to services rendered and income offered by the appellant in A.Y. 2020-21.

2. The Appellant has offered income in AY 2020-21 (FY 2019-20) and claimed TDS on the same in AY 2020-21 itself as per provisions of Sec 199 read with Rule 37BA sub-rule (3).

3. The deductor seems to have claimed expense in the subsequent year ie, AY 2021-22 & deducted tax in the subsequent year. The appellant has not claimed TDS credit in the subsequent year as it was already availed in previous year. Hence the difference.

4. That the Learned CIT(A) failed