TDS credit on dividends is confined to the registered shareholder unless Rule 30A specifically extends the benefit.

Credit for tax deducted at source on dividends is available only to the person described in section 199 as the shareholder, owner of the security, or other person covered by the statutory scheme. Where the assessee's name was not entered in the register of shareholders and the certificate under section 203 was not issued in her name, she could not claim TDS credit merely because the dividend was received in another person's name. Rule 30A extends credit to a non-shareholder only in the limited circumstances it specifies, subject to the prescribed declaration and certificate. The assessee was therefore not entitled to the credit.

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Issues: Whether the assessee, not being a registered shareholder, was entitled to credit for tax deducted at source on dividends received in the name of another person.

Analysis: Section 199 of the Income-tax Act, 1961 treats tax deducted as a payment on behalf of the person whose income is subjected to deduction, the owner of the security, or the shareholder, and credit is available only to the person answering that description. Rule 30A of the Income-tax Rules, 1962 extends credit to a person other than the shareholder only in the specific circumstances stated in the rule and subject to the prescribed declaration and certificate. The assessee's name did not appear in the register of shareholders, and the certificate required by section 203 was not issued in her name. The statutory scheme and the earlier authorities relied on make the registered shareholder, not merely the beneficial recipient of dividend, the person entitled to the credit unless the rule specifically applies.

Conclusion: The assessee was not entitled to credit for tax deducted at source on the dividends, and the answer was against the assessee and in favour of the Revenue.

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