Deloitte Haskins & Sells Vs DCIT (ITAT Delhi)
The appeal was filed by the assessee before the Income Tax Appellate Tribunal (ITAT), Delhi, against the order of the CIT(A)/NFAC dated 14.08.2025 for Assessment Year 2024–25. The primary grievance related to non-grant of full credit of Tax Deducted at Source (TDS), particularly where such TDS did not appear under the assessee’s Permanent Account Number (PAN) but corresponded to income offered to tax.
The assessee, a firm engaged in the profession of chartered accountancy, filed its return declaring income of ₹31.31 crore and claimed TDS credit of ₹11.64 crore. The return was processed under Section 143(1), but full TDS credit was not granted, resulting in a shortfall of ₹11,62,312.
Aggrieved, the assessee approached the CIT(A), who partly allowed the appeal for statistical purposes. The CIT(A) directed the Assessing Officer (AO) to verify the income declared and corresponding TDS credits across relevant years and allow credit accordingly, subject to availability in Form 26AS. However, the CIT(A) also directed that if TDS was not reflected under the assessee’s PAN, the assessee should ensure that the deductor revises the TDS return so that the credit reflects correctly before being allowed.
The assessee challenged this direction before the Tribunal, arguing that requiring it to ensure revision of TDS returns by the deductor was beyond its control. It was also submitted that TDS credits related to income already offered to tax, including amounts reflected in earlier or subsequent years’ Form 26AS and in the accounts of associate concerns.
