Conditions in rule 37BA should be read in provision of section 199(1) where no double credit is claimed

DCIT Vs Reliance Infrastructure Limited (ITAT Chennai) ITAT Chennai held that strict conditions provided in Rule 37BA should be read in the provisions of Section 199(1) to make it workable in genuine cases where department is sure no double credit is allowed or claimed. Facts- The assessee has claimed TDS credit of 68 Crores in the revised return of income filed on 27.05.2021. The return was processed u/s 143(1) vide Intimation dated 08.06.2022 wherein credit for TDS of Rs. 40.43 crore was not granted. The TDS credit of Rs. 40,42,92,666 which has not been granted by the CPC is in respect of th...