Assessee is  governed by Portuguese Civil Code as in force in State of Goa and was covered under special provisions of section 5A. He declared half of income earned in his return of income and apportioned half of income with his spouse in terms of section 5A  Assessing Officer processed return by giving apportioned TDS credit. Commissioner (Appeals) held that assessee was not entitled to entire TDS credit in his hands. On appeal the Tribunal held that  as per section 198 all TDS amounts deducted under chapter XVII are indeed deemed as income received of concerned assessee and legislative expression ‘assessee’ must be read as ‘spouses assessees’ in light of section 5A and, therefore, such TDS amount had to be consequentially apportioned going by scheme of Act. Order of CIT(A) is affirmed. (AY. 2018-19)