TDS credit follows assessable income, and mismatched certificate details cannot defeat entitlement when no one else claims the credit.

Credit for tax deducted at source cannot be denied merely because the certificate names an earlier bond holder or mentions a different assessment year, where the income is assessable in the assessee's hands and no other person has claimed the credit. Applying section 199 of the Income-tax Act, 1961, the Tribunal accepted that the assessee had acquired the bonds, was entitled to the related interest income, and had offered that income to tax in the relevant year. The assessee was therefore entitled to the TDS credit and refund, and the Revenue's objection was rejected.

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Issues: Whether credit of tax deducted at source could be denied merely because the certificate stood in the name of the earlier bond holder and mentioned a different assessment year, when the income was assessable in the assessee's hands and no other person had claimed the credit.

Analysis: The assessee had acquired the bonds and was entitled to the interest income. The deductor and the earlier bond holder confirmed that the assessee was the person entitled to the TDS benefit, and the assessee had offered the corresponding interest to tax in the relevant assessment year. Under section 199 of the Income-tax Act, 1961, credit for tax deducted at source is to be given to the person in whose hands the income is assessable, and the mere fact that the TDS certificate mentioned the previous holder or an earlier assessment year did not defeat that entitlement. The Tribunal also noted that the assessee had not claimed the same credit in any other year.

Conclusion: The assessee was entitled to the TDS credit and refund, and the Revenue's objection based on the name in the certificate and the assessment year mentioned therein was rejected.

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