Sanjay Ramchandra Gawande Vs ACIT (ITAT Pune)
Pune ITAT Upholds Denial of TDS Credit in Rectification; Wrong Deductor Details Cannot Be Corrected U/s 154
The Pune ITAT dismissed the assessee’s appeal and upheld the rejection of a rectification application under Section 154 of the Income-tax Act relating to denial of TDS credit. The assessee admitted that while filing the return for AY 2015-16, the name of the deductor was incorrectly entered as “SMC Infrastructure Pvt. Ltd.” instead of “Municipal Council, Kamtee, Nagpur,” resulting in a mismatch and restriction of TDS credit to ₹3,87,988 instead of the claimed ₹14,27,420 in the Section 143(1) processing. The assessee sought rectification under Section 154, which was rejected by the Centralized Processing Center and confirmed by the CIT(A). The Tribunal observed that the incorrect deductor details were entered by the assessee, the Section 143(1) processing was computer-generated without manual intervention, and allowing the additional TDS credit would require detailed verification of TDS documents, including Form 26AS and other records. It held that such verification falls outside the scope of Section 154, as the issue was not a mistake apparent from the record. Accordingly, it upheld the orders of the CPC and the CIT(A) and dismissed the appeal.
The Pune ITAT dismissed the assessee’s appeal and upheld the rejection of a rectification application u/s 154 seeking grant of TDS credit of ₹10.39 lakh. The assessee had correctly disclosed the income in the return but had inadvertently mentioned the wrong name of the deductor, resulting in a mismatch during CPC processing. Consequently, while processing the return u/s 143(1), the CPC restricted the TDS credit to ₹3.87 lakh instead of the claimed ₹14.27 lakh.
The Tribunal observed that the mistake originated from the assessee’s own incorrect data entry in the return of income. Since the CPC processes returns through an automated system without manual intervention, the mismatch could not be treated as a mistake apparent from the record. The Tribunal held that allowing the additional TDS credit would require verification of running bills, Form 26AS and other supporting documents, which involves detailed factual examination beyond the limited scope of section 154.
Holding that such verification cannot be undertaken in rectification proceedings, the ITAT ruled that the CPC was justified in rejecting the rectification application, and the CIT(A) had rightly confirmed the same. Accordingly, the assessee’s appeal was dismissed.
FULL TEXT OF THE ORDER OF ITAT PUNE
This is an appeal filed by the assessee against the order of the Learned Additional/Joint Commissioner of Income Tax (Appeals)-2, Bengaluru [Ld. Addl./JCIT(A)], passed u/s. 250 of the Income Tax Act, 1961 (‘the Act’) for AY 2015-16 on 23.02.2026.
