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Issues: Whether the assessee could be denied TDS credit merely because the credit reflected in Form 26AS did not fully match the TDS certificates produced by it, and whether the Revenue was obliged to verify the claim and allow credit for tax duly deducted and deposited.
Analysis: The assessee furnished the TDS certificates and related details to substantiate that tax had been deducted from its income and deposited to the credit of the Central Government. Form 26AS was treated as part of the Revenue's verification mechanism, but not as conclusive against the deductee so as to shift the entire burden onto the assessee. The mismatch in Form 26AS could arise from matters within the Revenue's domain, including incorrect reporting by the deductor, and the assessee could not be penalised for such discrepancy once the primary onus of proving deduction was discharged. The Revenue remained entitled to verify the claim and ensure compliance with the statutory conditions for grant of credit.
Conclusion: The assessee was entitled to TDS credit for the shortfall, subject to verification that the tax was in fact deducted and deposited and subject to the statutory conditions.
Ratio Decidendi: Production of TDS certificates discharges the assessee's primary burden for claiming TDS credit, and the Revenue cannot deny such credit solely on the basis of a Form 26AS mismatch without pointing out an infirmity in the claim after due verification.