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Issues: Whether the assessee, as the legal heir who has offered the deceased's interest income in her return, is entitled to the corresponding TDS credit despite the TDS being reported against the deceased person's PAN.
Analysis: The assessee, as legal heir, disclosed the interest income of the deceased in her return and claimed the corresponding TDS credit. The TDS was reported by the deductor against the deceased's PAN and therefore did not reflect in the assessee's Form 26AS, resulting in denial of credit by CPC and rejection of rectification. Rule 37BA governs allocation of TDS credit as per the PAN shown in deductor's statement; however, denial of credit on technical PAN-matching grounds where the taxpayer has offered the income would require the deductor to revise historical TDS statements, which may be impracticable. The claim was examined on its merits and accepted as an entitlement arising from offering the income for tax in the legal heir's return.
Conclusion: The TDS credit claimed by the assessee as legal heir is allowed and CPC is directed to grant the impugned TDS credit and revise the tax demand in respect of AY 2019-20 in favour of the assessee.
Ratio Decidendi: Where a legal heir offers a deceased person's taxable income in the legal heir's return, the corresponding TDS credit is allowable to the legal heir despite the TDS being reported against the deceased's PAN, and administrative PAN-matching technicalities do not preclude granting the credit.