2026 (3) TMI 699

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....artment : Ms. Harpreet Kaur Hansra, Sr. DR ORDER PER VIMAL KUMAR, JM: The appeal filed by the Assessee is against order dated 04.07.2025 of the Learned Addl./ Joint Commissioner of Income Tax (Appeals)-2, Pune [hereinafter referred to as 'the Ld. CIT(A)'] passed u/s 250 of the Income Tax Act, 1961, [hereinafter referred to as 'the Act'] arising out of rectification order u/s 154 of the Ac....

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....ant assessee preferred present appeal on following grounds of appeal: "1. That the Ld. CIT(A) has erred in upholding the order of the Ld. CPC, Bengaluru disallowing the TDS Credit of Rs. 1,23,700/- to the appellant. 2. That the Ld. CIT(A) has erred in deciding the case of the appellant for the concerned AY against him merely on change in opinion as the similar issue has been deci....

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....aid rival contention, it is crystal clear that the Ld. CIT(A) vide order dated 04.07.2025 upheld disallowing of TDS credit of Rs. 1,23,700/- by Ld. AO for AY 2022-23. On the contrary, Ld. CIT(A) vide order dated 21.02.2024 for AY 2023-24 had directed Ld. AO to give credit for TDS claim made by assessee considering the commission reported by the appellant as the turnover and determine the refund ac....