Rule 37BA Cannot Override Section 5A While Granting TDS Credit to Goa Residents

Sidhesh Mohan Raikar Vs DCIT (ITAT Pune)

Rule 37BA can’t override Section 5A: Goa resident under Portuguese Civil Code entitled to full TDS credit — ITAT Pune

Pune Tribunal allowed Assessee’s appeal & directed grant of full TDS credit of ₹45.28 lakh, rejecting proportionate restriction applied by CPC u/s 154 by invoking Rule 37BA. Tribunal held that Assessee, being a resident of Goa governed by Portuguese Civil Code, 1860, is squarely covered by s.5A, under which income (other than salary) is required to

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