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    <title>2022 (9) TMI 705 - ITAT MUMBAI</title>
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    <description>Income cannot be taxed merely because TDS appears in Form 26AS if real accrual to the assessee is not established. The ITAT Mumbai noted that the copyright society collected royalty and licence fees on behalf of members and recognised revenue only when usage logs were received, invoices were raised, and the relevant member was identified. As this consistent method of accounting was followed and the disputed receipts remained uncertain, the addition for unreconciled TDS and alleged income not offered to tax was held unsustainable, and the deletion by the first appellate authority was upheld.</description>
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      <link>https://www.taxtmi.com/caselaws?id=427760</link>
      <description>Income cannot be taxed merely because TDS appears in Form 26AS if real accrual to the assessee is not established. The ITAT Mumbai noted that the copyright society collected royalty and licence fees on behalf of members and recognised revenue only when usage logs were received, invoices were raised, and the relevant member was identified. As this consistent method of accounting was followed and the disputed receipts remained uncertain, the addition for unreconciled TDS and alleged income not offered to tax was held unsustainable, and the deletion by the first appellate authority was upheld.</description>
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