2025 (12) TMI 1110

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....For the sake of convenience, all the appeals filed by the Revenue and the Cross Objections filed by the assessee were heard together and are being disposed of by this common order. ITA No.691/PUN/2025 (A.Y. 2021-22) 2. Facts of the case, in brief, are that the assessee is a private limited company incorporated to build, construct, operate and maintain the container port terminal under the license agreement with the Govt. of India through JNPT. It filed its return of income on 14.03.2022 declaring total income of Rs. 44,51,67,190/- and claiming TDS credit of Rs. 14,53,99,188/-. The return was processed u/s 143(1) of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') and an intimation dated 22.09.2022 was issued wherein TDS....

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....n the facts and circumstances of the case and in law, the Ld. CIT(A) erred in not appreciating the fact that the when the TDS credit is claimed entirely as per the provisions of Act, the entire revenue should have been offered by the assessee. c. The appellant prays that the order of the CIT(A) may be set aside and that of the assessing Officer be restored. d. The appellant craves leave to add, alter, amend and modify any of the above grounds of appeal either before or at the time of hearing of the appeal, if considered necessary. 6. We have heard the rival arguments made by both the sides, perused the intimation of the Assessing Officer (CPC) and the order of Ld. Addl./JCIT(A). We have also gone through the paper book ....