ITAT Mumbai Allows TDS Credit to Transferees Despite Certificates Being in Merged/Split Company's Name

The Mumbai ITAT directed the AO to allow TDS credit to transferees, even if certificates are in the name of amalgamated/demerged companies. Despite Rs. 8.13 crore TDS credit denial, taxpayer argued for credit, citing assessed income. The tribunal ruled in favor, instructing AO to verify and grant credit. \r

Additionally, the dispute over Provision for Expenses arose. Taxpayer's provision, disallowed 30%, contested under Section 40(a)(ia). AO disallowed remaining 70%, alleging adhoc basis. ITAT found provision ascertained, voiding AO's decision, deleting the 70% addition of Rs. 109.46 crore.