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2025 (6) TMI 1049

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....:- This appeal by the revenue is preferred against the order dated 22.08.2024 by NFAC, Delhi pertaining to AY 2011-12. 2. The grievance of the revenue reads as under: "Whether on the facts and in the circumstances of the case and in law, the CIT(A) was justified in allowing the appeal of the assessee on the ground of credit against physical TDS certificate to the extent of Rs. 7,78,54,395/- wh....

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....redit to TDS as claimed by the assessee. 4. Before us, the DR strongly contended that without verifying the facts, the TDS credit cannot be allowed and prayed for the modification of the finding of the CIT(A). 5. Per contra, the counsel strongly stated that once the tax credit is supported by valid TDS certificate, there is no question of any verification and denial. In support of his contention....

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.... Yashpal Sahni 293 ITR 539. It is equally true that the decision of the coordinate bench mentioned hereinabove has been upheld by the Hon'ble High Court of Bombay mentioned hereinabove. 7. We find that while upholding the order of the coordinate bench, the Hon'ble High Court held that, "Resultantly, the Tribunal only directed the AO to verify the correct facts and give credit of TDS to the assess....