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198 of the Act. The TDS credit of Rs. 2,48,71,145/- on deferred revenue will be allowed in the relevant assessment year in which underlying revenue has been offered to tax.
Further, the assessee has claimed additional TDS of Rs. 12,70,656/-during the course of assessment proceedings. However, assessee company had not claimed the above TDS of Rs. 12,70,656/- in the return of income. In view of the decision of the Hon'ble Supreme Court in the case of Goetze IndiaLtd. Vs CIT [284 ITR 223], the deduction could not be made without a valid revised return. Since in the instant case the return has not been revised within the meaning of section 139(5) of the I. T. Act, 1961 therefore the additional claim of TDS of the assessee company can't be accepted and is hereby rejected. Since, I am satisfied that the assessee has furnished inaccurate particulars of its income, penalty proceedings under section 271(l)(c) are being initiated separately.