
Case Law Analysis
|Income Tax Appellate Tribunal
Section 199 + Rule 37BA | TDS Credit Allowed to Assessee Even When Deducted Under Associate’s PAN, If Income Taxed in Assessee’s Hands : ITAT Delhi
The ITAT Delhi has ruled that an assessee is entitled to TDS credit even if the tax deduction is reflected under an associate’s PAN, provided the income is genuinely taxed in the assessee’s hands and no double benefit arises. This reinforces the doctrine of substance over form in tax administration, protecting businesses with shared economic structures from unjustified denial of statutory credits.