Yamaha Motor Solutions (India) Pvt. Ltd. Vs PCIT (ITAT Delhi)
TDS credit, being prepaid tax, cannot be denied when it has already been allowed in a rectification order and there is no dispute regarding mismatch or non-reporting of the corresponding income.
Issue: Whether denial of TDS credit of ₹99,54,581 in the assessment order under section 143(3) was sustainable when the same credit had already been granted by the Revenue in an order under section 154, and whether consequential interest under sections 234A and 234B could survive.
Facts: The assessee filed its return for AY 2018-19 claiming TDS credit of ₹99,54,581. Though the credit was initially denied in the intimation under section 143(1), the mistake was rectified by the Assessing Officer through an order under section 154 dated 23.09.2020 granting full credit. Subsequently, while completing assessment under section 143(3), the Assessing Officer again failed to grant the same TDS credit and levied interest under sections 234A and 234B. The CIT(A) dismissed the appeal on the ground that the issue arose from the intimation under section 143(1).
Tribunal’s Findings: The Tribunal held that the CIT(A) failed to appreciate the correct factual position. Once the mistake in the intimation under section 143(1) had already been rectified by an order under section 154, no grievance survived against the intimation. The denial in the scrutiny assessment was evidently due to the Assessing Officer overlooking his own rectification order.
