Kanika Satyanand Vs ITO (ITAT Delhi)
She Asked for Half the TDS; the Tribunal Shifted All the Income to Her Brother
A mismatch between income and Form 26AS
Kanika Satyanand offered to tax a 50% share of income received from Zodius funds for assessment year 2024–25 and claimed the corresponding TDS credit of ₹2,22,988. The difficulty was that the deductors had reported the entire TDS under her brother Mohit Satyanand’s PAN. The credit claimed by Kanika was denied during processing, and the NFAC upheld that denial.
The figures recorded by the Delhi ITAT were that total income of ₹44,59,794 had been credited and TDS of ₹4,45,979 deducted under Section 194LBB. Mohit reported ₹22,29,988, representing half the income, and claimed approximately half the TDS. Kanika said she had reported the remaining half and should receive the matching TDS credit. Her appeal concerned ₹2,22,988, not a claim for credit of the entire deduction.
The case therefore presented a familiar problem: the income is offered in one person’s return, while the TDS appears against another person’s PAN. Kanika relied on Section 199 read with Rule 37BA, arguing that credit should follow the person who offered the corresponding income to tax.
What Kanika asked the Tribunal to do
