TDS credit cannot be denied without mismatch or legal deficiency, and consequential interest under sections 234A and 234B falls away.

TDS credit cannot be denied where the tax has already been deducted at source and the revenue shows no mismatch, deficiency, or failure to offer the corresponding income. Here, the assessee's TDS credit claim was initially rejected in processing but later rectified under section 154, leaving no live dispute on the processing adjustment. The denial in the assessment order was treated as an inadvertent omission, and the credit was held allowable. Once the TDS credit was accepted, interest under sections 234A and 234B also could not survive and was directed to be deleted.

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Issues: Whether the assessee was entitled to TDS credit of Rs. 99,54,581/- and, consequentially, whether interest under sections 234A and 234B could survive.

Analysis: The TDS credit claimed by the assessee had initially been denied in processing under section 143(1), but the mistake was later rectified under section 154. In that situation, there remained no live grievance regarding the processing order. The denial of credit in the assessment order was treated as an inadvertent omission, and the revenue did not show any mismatch, deficiency, or failure to offer the corresponding income to tax. Since tax paid by way of TDS is a rightful credit due to the assessee, it could not be denied merely because of such omission. Once the TDS credit was held allowable, the levy of interest under sections 234A and 234B also could not stand.

Conclusion: The issue was decided in favour of the assessee. The assessee was held entitled to the TDS credit, and the consequential interest under sections 234A and 234B was directed to be deleted.

Ratio Decidendi: TDS credit, being tax already paid on behalf of the assessee, cannot be denied in the absence of mismatch or other legal deficiency, and any consequential interest based on such wrongful denial cannot survive.

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