Dismissing the appeal of the Revenue the Court held that the CBDT is empowered to frame rules that may be necessary to give credit to a person “other than those referred to in sub-s. (1) and sub-s. (2)…” of s. 199-Therefore, S. 199, read in its entirety, does not limit credit only to those deductees whose deductors have deposited the amount with the Central Government-Moreover, the expression “and paid” to the Central Government found in S. 199(1) must be contextualized in the setting in which it is placed, i.e., Chapter XVII, whereby, the sanctions for failing to deposit tax with the Central Government are laid on the payor/deductor-Significantly, Chapter XVII contains provisions for penalizing the payer/deductor when he fails to deposit the tax deducted at source with the Central Government. The Act does not seem to cast a burden on the deductee/payee with regard to the deposit of money, which is retained as tax, by the payer ie., the deductor. Therefore, insofar as the deductee/payee is concerned, once the payer/deductor, who acts as an agent  of the Central Government, has retained money towards tax, credit for the same cannot be denied, having regard to the consequences and the modes available for recovering the said amount from the payer/deductor. Followed  Sanjay Sudan v. ACIT  (2023) 331 CTR  797/  224 DTR  9 (Delhi)(HC).