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INCOME TAX APPELLATE TRIBUNAL (HYDERABAD BENCH)
Ravish Sood, Judicial Member, Madhusudan Sawdia, Accountant Member
R.K. Distilleries Private Limited – Appellant
Versus
Income Tax Officer, Ward-3(1), Hyderabad – Respondent
| Table of Content |
|---|
| 1. tds mismatch due to assessee's income offer in ay 2020-21 versus deductor's later accounting. (Para 8) |
| 2. rule 37ba(3)(i) mandates tds credit in year income assessable, supported by precedents. (Para 9) |
| 3. direct ao to grant tds credit in ay 2020-21, prevent double credit. (Para 10 , 11) |
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 Ru
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