The ITAT allowed the appeal of the assessee, holding that as the...

The ITAT allowed the appeal of the assessee, holding that as the assessee acted solely as a commission agent, the gross sale proceeds cannot be treated as its income for the purpose of TDS credit under sections 194Q and 194A. The Tribunal relied on precedents establishing that an agent is entitled to credit for the entire TDS amount deducted, and found no shortfall in TDS. Consequently, the orders of the Revenue Authorities denying TDS credit under Rule 37BA of the Income Tax Rules were set aside. The matter was remanded with a direction to the AO-CPC to grant the assessee full credit of the TDS amount deducted.