Assistant Commissioner Of Income Tax, ... vs Ravi Infrabuild Projects Limited, ... on 30 October, 2025
4. Before the CIT(A), the assessee submitted that certain invoices were raised
in March 2022 (relevant to AY 2022-23) and the income therefrom was already
offered to tax in that year; however, deductors deducted and deposited TDS in
April 2022 (FY 2022-23), hence the credit appeared in Form 26AS of the year
under appeal. It was also explained that some deductors computed TDS
on GST-inclusive amounts, causing a mismatch. Reliance was placed on Rule
37BA(3)(i) and decisions including NCC Maytas JV v. ACIT and ITO v. Adani
Vizhinjam Port Pvt. Ltd..