2024 (1) TMI 1324

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....O) u/s 143(3) r.w.s. 144C(13) of the Act pursuant to the directions of Ld. Dispute Resolution Panel-2, Bengaluru (DRP) u/s 144C(5) of the Act dated 27-12-2022. The sole substantive grievance of the assessee is denial of Tax Deducted at Source (TDS) credit by lower authorities. The grounds raised by the assessee read as under: 1.1. The order of the learned Assessing Officer ("AO") and the Hon'ble Dispute Resolution Panel ("DRP") is contrary to canons of equity and natural justice, contrary to law and facts involved, not based on facts and circumstances of the case, contrary to mandatory provisions of the Income tax Act, 1961 ("Act"), lacks jurisdiction and is liable to be struck down. 1.2. On the facts and the circumsta....

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..... and offered the same to tax. However, in the financial statements, the assessee offered royalty income of Rs. 37.86 Crores whereas as per Form 26AS, the payer entity paid an amount of Rs. 69.83 Crores to the assessee after deducting tax at source for Rs. 7.62 Crores. 4. The assessee explained that the amount reflected in Form 26AS represents gross invoices raised by the assessee which, in turn, are based on the amounts reported by the deductor payer in its TDS returns. However, the assessee has raised few credit notes subsequent to raising of invoices which were not reflected in Form 26AS since the same would not have any TDS implications. It was also explained that the assessee raised invoices for Rs. 72.93 Crores against which credit....