Urmilaben H. Dave Disc Family Trust Vs ITO (ITAT Ahmedabad)
Income Tax Appellate Tribunal (ITAT) Ahmedabad, in a recent ruling on May 30, 2025, has remanded the appeals of Urmilaben H. Dave Disc Family Trust back to the Assessing Officer (AO). The case involves the trust’s claim for TDS (Tax Deducted at Source) credit, which had been denied in the intimation under Section 143(1) of the Income Tax Act, 1961, for assessment years 2020-21, 2021-22, and 2022-23. The ITAT noted that the AO had neither formally rejected nor accepted the trust’s rectification applications for the TDS credit.
For the assessment year 2020-21, the trust had filed its return declaring an income of ₹3,52,130 and claimed a refund. However, the intimation under Section 143(1) on October 21, 2021, disallowed a TDS credit of ₹35,493. The trust subsequently filed a rectification application under Section 154 on April 13, 2023, for this credit. When no action was taken, a CPGRAM (Centralized Public Grievance Redress and Monitoring System) application was filed on April 11, 2024, which was simply “closed” on April 23, 2024, without addressing the TDS claim, leading to a demand of ₹5,470. Similar situations arose for A.Y. 2021-22 and 2022-23, with TDS credits of ₹29,880 and ₹41,697 denied, respectively, and corresponding demands raised.
