Actual receipt and verified TDS details govern taxation of enhanced compensation interest; Form 26AS alone is not conclusive.

Interest on enhanced compensation for compulsory land acquisition was treated as requiring verification of actual receipt and matching TDS particulars before assessment. Where PAN and TDS details appeared inconsistent, including a mismatch between the payer's statement and Form 26AS, the factual position had to be examined afresh. Mere reflection of TDS in Form 26AS was noted as insufficient by itself to fasten tax liability if the corresponding interest had not been credited to the assessee or if tax had been deducted under the wrong PAN. The matter was restored for fresh adjudication after reasonable opportunity of hearing.

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Issues: Whether the interest stated to have been received on enhanced compensation for compulsory acquisition of land was to be assessed only on the basis of actual receipt and verified TDS particulars, and whether the matter required restoration for fresh examination.

Analysis: The assessee asserted that no proper notice had been received and that the record reflected an apparent inconsistency in PAN and TDS details, including a mismatch in the statement furnished by HSIIDC and the Form 26AS entries. The Tribunal held that the factual position needed verification and that assessment should proceed only on the amount actually received by the assessee. It also observed that mere reflection of TDS in Form 26AS would not by itself fasten tax liability if the corresponding interest had not been credited to the assessee or if TDS had been wrongly deducted under the assessee's PAN without credit being taken.

Conclusion: The matter was restored to the Assessing Officer for verification of facts and fresh adjudication on merits after giving reasonable opportunity of hearing to the assessee.

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