This document provides a thorough analysis of the Income Tax Appellate Tribunal (ITAT) decision for the appeal filed by Indigo Infraprojects Pvt. Ltd against the Assistant Commissioner of Income Tax, Circle-10(1), Delhi for the Assessment Year 2019-20. The appeal concerns the disallowance of carried forward TDS credits.
The primary dispute revolves around the rejection of a carried forward TDS credit claim worth Rs.9,94,719 by the Central Processing Centre (CPC), which was upheld by the CIT(A). The company contested that the related income corresponding to the TDS was declared in the Income Tax Return of the said year, arguing the merits of the claim under section 199 read with rule 37BA of the Income Tax Act.
Indigo Infraprojects argued the procedural inconsistencies in the processing of their tax return and the misinterpretation of the rules governing TDS credits. The tribunal’s analysis focused on whether the TDS credit was rightly carried forward and whether the corresponding income was duly declared, leading to a decision that highlighted the need for a detailed verification of the claims by the Assessing Officer (AO).
The ITAT’s decision to remand the matter back to the AO for verification underscores the judiciary’s approach towards ensuring that tax credit claims are substantiated with accurate and complete disclosures. This case is significant for taxpayers and practitioners dealing with issues related to the carry forward and set off of TDS credits.
Order pronounced on the open court on 2023-03-16.
TDS Credit Dispute for Indigo Infraprojects Pvt. Ltd for AY 2019-20
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