TMI Blog2004 (11) TMI 506X X X X Extracts X X X X X X X X Extracts X X X X ..... Income-tax Act, 1961. 2. Among other things, the assessee in this case had also income by way of interest accrued on bank deposits, as far as the impugned assessment years are concerned. As the assessee was following the cash method of accounting, the interest accrued on the bank deposits has not been recognised by the assessee as her income. The interest income is recognised on the maturity of the deposits. 3. Even then, the banks had to deduct tax at source on the amount of interest accrued on the bank deposits of the assessee. Therefore, the Banks deducted tax at source on the amounts of interest credited in favour of the assessee during the previous years relevant to the assessment years under appeal. 4. The assessee in its ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he assessee for the impugned assessment years alone will be taken into credit for determining the ultimate tax liability of the assessee for the impugned assessment years. The assessee is aggrieved on this direction and therefore these appeals before us. 6. We heard both sides in detail. The CIT(Appeals) has stated that the credit for the TDS has to be given in the year in which the income is assessed. He observed that in case the appellant has not offered any interest income for the relevant assessment years or offered only a part of the income for these years, then the Assessing Officer will give credit for the TDS proportionately to the income offered by the appellant for the concerned assessment years. 7. We are unable to agree ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r as tax collected at source or as self-assessment tax shall be considered for the concerned assessment year itself. 9. The position is further made clear by sub-section (4) of section 143, which is extracted below : "(4) Where a regular assessment under sub-section (3) of this section or section 144 is made, ( a )any tax or interest paid by the assessee under sub-section (1) shall be deemed to have been paid towards such regular assessment;" 10. The mode of computation of tax liability on an assessment after reckoning the various credits available to an assessee is well explained in the provisions of law extracted above. Therefore, in substance the tax deducted at source must be attributed to the concerned assessment year and ..... X X X X Extracts X X X X X X X X Extracts X X X X
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