Appellate Tribunal grants TDS credit refund for 2018-19, overturning CIT decision.

The Appellate Tribunal ruled in favor of the appellant, directing the jurisdictional AO to grant the refund of TDS credit for the assessment year 2018-19. The Tribunal emphasized that TDS credit should be given for the assessment year in which the corresponding income is assessable, overturning the decision of the CIT (Appeals). Consequently, the appellant's appeal was allowed, providing relief regarding the denial of TDS credit.

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Issues involved:
The issues involved in the judgment are the validity of the order passed by the Commissioner of Income Tax (Appeals), the denial of TDS credit, the charging of interest under sections 234B and 234C of the Income Tax Act, and the condonation of delay in filing the appeal.

Validity of Order by CIT (Appeals):
The appellant contended that the order passed by the Commissioner of Income Tax (Appeals) was invalid and bad in law as the appellant's submissions were not considered during the appellate proceedings. Despite offering to explain the facts through virtual hearing, the CIT (Appeals) did not take this into account, leading to the appellant filing a grievance on the Income Tax Portal which remained unresolved.

Denial of TDS Credit:
The appellant had claimed TDS credit as per the provisions of section 199 of the Income Tax Act read with Rule 37BA(3)(i) of the Income Tax Rules. The appellant argued that the credit for tax deducted at source and paid to the Central Government should be given for the assessment year for which such income is assessable. However, the CIT (Appeals) failed to consider this provision and disallowed the TDS credit, leading to the appellant's appeal.

Charging of Interest under Sections 234B and 234C:
The appellant challenged the charging of interest under sections 234B and 234C of the Income Tax Act as invalid and bad in law. The appellant sought relief from the interest charges imposed by the tax authorities.

Condonation of Delay in Filing Appeal:
The appellant's appeal was time-barred by 96 days, and the appellant provided an affidavit to explain the delay. The delay was attributed to efforts made by the appellant to resolve the issue with the jurisdictional AO and the TDS officer, leading to the delay in filing the appeal. The Tribunal found the explanation reasonable and condoned the delay, allowing the appeal to be heard on its merits.

Summary of Judgment:
The Appellate Tribunal, after considering the arguments presented by the appellant and reviewing the relevant documents, found in favor of the appellant. The Tribunal directed the jurisdictional AO to grant the refund of TDS credit to the appellant for the assessment year 2018-19. The Tribunal emphasized that the benefit of TDS should be given for the assessment year for which the corresponding income is assessable, overturning the decision of the CIT (Appeals). As a result, the appeal of the appellant was allowed, providing relief in the matter of TDS credit denial.

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