2025 (12) TMI 1095

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....024-25. 2. The assessee has raised the following grounds of appeal: 3. The brief facts of the case are that the assessee is a company and filed its return of income for the Assessment Year 2024-25 on 29.10.2024 declaring a total loss of Rs. 38,61,336/-. During the year, total TDS of Rs. 6,66,366.44 was deducted in the case of the assessee and such deduction was duly reflected in Form No.26AS. However, while filing the return of income, the assessee inadvertently did not claim credit of the said TDS. Consequently, the Centralized Processing Centre ("CPC"), while processing the return of the assessee under section 143(1) of the Income Tax Act, 1961 ("the Act") vide intimation dated 29.10.2024, did not grant credit for the TDS. 4. Agg....

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....ilable on record. It is not in dispute that TDS is reflected in Form No.26AS in the name of the assessee. In this regard, it is crucial to go through the provisions of Section 199 of the Act, which is to the following effect: "199. (1) Any deduction made in accordance with the foregoing provisions of this Chapter and paid to the Central Government shall be treated as a payment of tax on behalf of the person from whose income the deduction was made, or of the owner of the security, or of the depositor or of the owner of property or of the unit-holder, or of the shareholder, as the case may be. (2) Any sum referred to in sub-section (1A) of section 192 and paid to the Central Government shall be treated as the tax paid on be....

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....e is allowed for statistical purposes. Order pronounced in the Open Court on 10th December 2025. ============= Document 1 1. Ground of appeal . Relevant Section of IT Act: 250 . Issue: Order is opposed to facts and law · Ground: The impugned order passed by the learned CIT(A) under section 250 of the Act is erroneous, contrary to law, and opposed to facts of the case. The Assessee disputes and challenges the findings recorded therein. 2. Ground of appeal . Relevant Section of IT Act: 250 . Issue: Order is opposed to facts and law . Ground: The learned CIT(A) erred in upholding denial of TDS credit of 26,66,366.44 for AY 2024-25 despite the credit reflecting in Form 26AS and tax having been duly deposited to t....