Assessee made adhoc payment of TDS on estimated basis. On finalization of bills of the contractors and sub-contractors, the actual TDS liability was determined. Thus, there was shortfall in payment of TDS for some years and excess deposit for some years. The AO did not adjust the excess deposit against the shortfall and raised the demand including interest u/s. 201(1A) of the Act. The Tribunal held that the stand taken by revenue was contrary to the communication issued by the CPC (TDS) which stated that excess deposit of TDS can be adjusted against the shortfall. The Tribunal further relied on Section 245 of the Act and held that the assesse was entitled for adjustment of the excess deposit of TDS made in earlier year against the TDS payable for subsequent years and directed the AO to recompute the amount payable/refundable to the assesse.