2026 (3) TMI 939

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..../Joint Commissioner of Income Tax (Appeals), Bhopal, ["learned Addl./Joint CIT(A)"], which in turn arose from the intimation issued under section 143(1) of the Act, for the assessment year 2021-22. 2. In this appeal, the Revenue has raised the following grounds: - 1. "On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in directing the Assessing Officer to allow credit of TDS not reflected in Form 26AS merely on the basis of the assessee's claim and indemnity bond, without ensuring that whether the tax so deducted had actually been deposited to the credit of the Central Government, as required under section 199(1) of the Income-tax Act, 1961 read with Rule 37BA of the Income-tax Rules, 1962." ....

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.... MUMR17318A 1,65,35,104 - 5,81,250 1,59,53,854 2 Apollo International Limited RTKA03479A 42,30,282 38,77,885 3,52,397 3 State Bank of India MUMS89583E 90,69,371 90,69,071 300 Total 2,98,34,757 1,29,46,956 1,68,87,801 5. After considering the submissions of the assessee, the learned CIT(A), vide impugned order, issued the following directions: - "4.1 I have considered the facts of the case, contention of the appellant and the intimation order u/s 143(1) of the Act. The appellant has submitted that, as per the latest Form No. 26AS, credit for TDS of Rs. 5,81,250/- is being reflected but credit is not granted. Further, the appellant has submitted that TDS of Rs. 1,59,53,85....