TDS credit in Form 26AS must be verified under section 199, with consequential refund interest following allowed credit.

TDS credit reflected in Form 26AS must be examined under section 199 and rule 37BA, and where the deduction has been duly remitted and the related income accounted for, credit cannot be denied on an objection outside the issue actually decided. The discussion also notes that consequential interest on the resulting refund follows the allowance of credit, subject to verification under the statutory credit mechanism. A challenge seeking to raise a different quantum-based objection was treated as beyond the scope of the limited controversy, and the revenue's appeal failed.

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Issues: Whether the assessee was entitled to credit for tax deducted at source reflected in Form 26AS and to consequential interest on refund, and whether the revenue could successfully challenge the order allowing such relief.

Analysis: The dispute before the lower appellate authority was confined to non-grant of TDS credit despite the deduction being reflected in Form 26AS and duly remitted, along with the related claim for interest on the resulting refund. The material on record showed that the dividend receipt had been considered in the return and that the claim for TDS credit had to be examined with reference to section 199 and rule 37BA. The order under challenge did not suffer from any error on this limited controversy. The revenue's attempt to raise a different objection about the quantum of income was outside the scope of the issue actually decided below.

Conclusion: The assessee was entitled to the TDS credit subject to verification under the statutory credit mechanism, and to consequential interest on refund. The revenue's appeal failed.

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