The Tribunal held that the  AO ought to have placed reliance on various judicial precedents wherein it is held that credit for TDS has to be provided to the Appellant irrespective of the year to which the income relates. The Tribunal further held that the  AO has erred in not following his assessment orders for previous years and thereby erred in not granting credit for TDS of Rs.13,735,965, which was denied in AY 2010-11. The AO ought not to have disallowed the TDS credit in respect of the entire advances considering that some portions of the advances were forming part of unbilled revenue and hence offered to tax. The Tribunal held that with regard to credit for tax deducted at source not given by the Assessing Officer despite directions by the Dispute Resolution Panel, the Assessing Officer was to consider the claim of the assessee afresh in accordance with the law. (AY.  2010-11, 2011-12)