TaxTMI 
TaxTMI 
2025 (3) TMI 982
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.... Advocate (Erode) (Virtual) For the Respondent : Ms. Anitha, Addl. CIT ORDER PER JAGADISH, A.M : Aforesaid four Miscellaneous Applications (MAs) have been filed by the assessee against the common order passed in ITA Nos. 890 to 893/Chny/2024 dated 31.07.2024 for rectification of mistake apparent on record in exercise of powers u/s. 254(2) of the Income-tax Act, 1961 (hereinafter "the Act"). Al....
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....und No.1 formed part of the order itself. However, the CIT(A) erred in not making any adjudication or finding as to the said submission; * Further, when the Applicant filed appeal before the ITAT, Chennai, Ground No.2 in Form 36 was raised with regard to non-consideration by the First Appellate Authority of the submissions made by the Applicant during first appeal, of which the plea to grant cre....
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.... * Therefore, the Applicant humbly prays that this Miscellaneous Application be entertained, adjudicated on merits and suitable directions may be given to the concerned authority for granting credit of TDS appearing in Form 26AS in the interests of justice." 3. The Ld. Authorized Representative (A.R) of the assessee has submitted that the assessee in ground No.1 of appeal filed before Ld CIT(A )....
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....r credit of TDS in view of section 199 of Income Tax and the A.O is duty bound to allow the same as per Rule. Coming to the MA, we find that the assessee has not raised the specific ground for grant of TDS in Form-36 before us. The Ld. AR has also not argued this ground during the course of hearing. We therefore are of the opinion that if the assessee has neither raised a specific ground, nor argu....