TDS credit Mismatch

This decision reinforces the primacy of substantive tax credit over procedural reporting gaps. The Tribunal rejected the approach of conditioning TDS credit on deductor compliance, an act beyond the taxpayer’s control, and clarified that once income is assessed in the hands of the assessee, the corresponding TDS must follow. 

By aligning with established jurisprudence on Section 199 and Rule 37BA, it ensures that system-driven mismatches do not translate into denial of legitimate credit. The ruling also limits the scope of CPC adjustments and strengthens taxpayer protection in cross-PAN and timing mismatch scenarios.