2025 (9) TMI 155

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....e following grounds of appeal: 1.1 The order uls 250 passed on 06.08.2024 by NFACICIT(A)], Delhi (for short "CIT(A) for A.Y. 2017-18 confirming prima facie adjustment by way of addition of Rs. 43,76,770/- being the difference in interest income between the amount shown in Form 26AS and return of income is wholly illegal, unlawful and against the principles of natural justice. 1.2 The Ld. CIT(A) has grievously erred in law and or on facts in not considering fully and properly the explanations furnished and the evidence submitted by the appellant. 2.1 The Ld. CIT(A) has grievously erred in law and or on facts in confirming the addition of Rs. 43,76,770/- being the difference in interest income between the amount sho....

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....on with regard to the discrepancy and reconciled the difference. It was pointed out that the interest on Bank of India capital gain scheme account was Rs. 23,62,375/- which was duly disclosed in the return of income but the bank had made TDS at 20% of Rs. 27,75,995/- thereof instead of the prescribed rate of 10% and thus TDS made was Rs. 5,55,199/- as per Form-26AS. The revenue determined that the gross amount of Rs. 55,51,990/- shown in Form-26AS by reverse calculation of 10 times the said TDS amount. The assessee had approached bank authorities and explained this mistake with the entries recorded in the passbook which also show interest of Rs. 27,75,995/-. The assessee had also explained the discrepancy with regard to the other interest i....

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.... 07.09.16 20% TDS Deducted by us Rs. 472475.00 (wrongly shown in section 194A in form 26AS) Saving's Account Credit by Rs. 18899900.50 (As per passbook on 07.09.16) 9. The bank also confirmed that the amount deducted was wrongly reflected u/s.194A as showing interest payment made while actually, they have deducted amount on their balance amount lying during the closure of the CGAS saving account. Thus, the BOI Branch Manager has given a letter categorically admitting wrongly deducted TDS. The bank statement of the assessee and also capital gain account statement of the assessee have been perused and the facts are found to be correct and without any dispute. 10. We find that the inability of the system to rectify an apparen....