Held that sub-rule (3)(i) of rule 37BA makes it clear that credit of TDS shall be allowed in the year in which relevant income is taxable. Therefore, where the assessee-company, as per the regularly followed method of accounting, had offered relevant income, out of which TDS was deducted, for taxation in the assessment year 2017-18, credit of TDS was to be allowed during the assessment year 2017-18 in accordance with the mandate of section 199 read with rule 37BA, even though payers had deducted TDS in financial year relevant to the assessment year 2018-19. Matter was remanded for verification. (AY. 2017-18)
Shivganga Drillers (P.) Ltd. v. CPC, Income-tax, Bangalore (2022) 195 ITD 555 (Indore) (Trib.)
S. 199 : Deduction at source-Credit for tax deducted-Income offered-Payer has deducted tax at source in financial year 2018-19-Credit for tax deducted at source has to be given in the year in which the income was offered for taxation. [S. 4, 198, Rule 37BA]