Assessee is engaged in the business of providing software. It raised invoice on Ashoka Leyland, Chennai in March 2011. Ashoka Leyland deposited the tax in April 2011 (succeeding financial year). The A.O. denied the credit by applying Rule 37BA(1) of the Income Tax Rules, 1962. The assessee submitted that benefits of tax deducted at source (TDS) should be allowed in the year in which the corresponding income is recorded.  The Tribunal considered rule 37BA, that grants TDS credit to a person, to whom payment is made, or credit has been given, based on information furnished by the deductor. There is no denial to the TDS by Ashok Leyland. Rule 37BA(3) provides for the “point of time” at which the benefit of TDS is granted. It equivocally provides for credit on tax deducted at source in the year in which income is assessable. Applying the rule, it allowed the TDS credit.   (AY. 2011-12)