BAE Systems Information and Electronic Systems Integration Inc. v. Add. CIT (IT) [2023] 105 ITR 18 (SN) (Delhi) (Trib)

S. 199: Deduction at source-Credit for tax deducted-Income declared on accrual basis when the software was sold-Eligible to claim TDS in the year when income was offered for tax. [S. 145]

It has been held by the Hon’ble Appellate Tribunal that the assessee had raised invoices during the year under consideration and had also shown revenue from the invoices as income during the year under consideration itself. The deductors may have deducted tax in subsequent assessment years, however as the assessee had shown income from sale of software during the year under consideration, the assessee had every right to get credit for the tax deducted at source in the impugned year itself. (AY. 2019-20)