Section 205: Bar Against Direct Demand on Assessee When TDS is Deducted

1. Core Principle (Tax Credit Mechanism)

  • Shield for Taxpayers: When tax has been duly deducted at source (TDS)and deposited to the government, the Income Tax Department cannot demand the same tax again from the recipient (assessee).
  • Objective: Prevents double taxationon the same income.

2. Conditions for Protection

For Section 205 to apply:

  • TDS must be correctly deductedas per applicable rates.
  • Tax must be actually depositedwith the government (visible in Form 26AS).
  • Income must be declaredin the assessee’s tax return.

3. Exceptions Where Protection Fails

The bar does not apply if:

  • TDS was not deducted(even if assessee pays tax later).
  • Deductor didn’t depositTDS with the government.
  • Income is concealed(not shown in ITR).
  • Wrong PAN quoted(TDS credit not traceable to assessee).

4. Judicial Precedents

CASE RULING
Hindustan Coca-Cola (SC 2007) Tax credit allowed even if deductor defaults in deposit
Yashpal Sahni (SC 2007) Assessee can’t be harassed for deductor’s mistakes
CIT vs. Kotak Securities (2013) Protection applies only for tax actually deposited

5. Practical Implications

  • For Employees/Salaried Persons:
    • No additional demand if Form 16 shows proper TDS.
    • Must reconcile Form 26AS with Form 16.
  • For Business Recipients:
    • Can claim expense deduction only if TDS deposited (Section 40(a)(ia)).
    • Need to follow up with clients for missing TDS credits.

6. Recovery Process When TDS Not Deposited

  1. Department Action:
    • Recover from deductorfirst (Section 201).
    • Approach assessee only if recovery from deductor fails.
  2. Assessee’s Rights:
    • Can demand indemnityfrom deductor.
    • May claim refundif tax paid twice (via rectification).

7. Recent CBDT Clarifications (2023)

  • Form 26AS Matching: Mandatory for processing refunds.
  • TRACES Verification: Deductors must resolve mismatches within 30 days.
  • Pre-assessment Notices: Now specify whether demand arises from TDS shortfall.

8. Proactive Protection Measures

  1. Quarterly Checks:
    • Verify TDS credits in Form 26AS/AIS.
    • Reconcile with books of account.
  2. For Missing Credits:
    • Approach deductor for correction statement.
    • File Form 71 for manual credit (with bank challan proof).
  3. Dispute Resolution:
    • File rectification under Section 154.
    • Seek stay of demand during appeal.

Example: A consultant receives ₹10L fee with ₹100K TDS shown in Form 16A. If this appears in Form 26AS, the department cannot demand ₹100K again – even if the client hasn’t deposited it (though the client may face penalties).

Key Takeaway: While Section 205 provides vital protection, taxpayers must actively verify TDS credits and maintain documentation to invoke this safeguard effectively. For high-value transactions, consider obtaining advance tax rulings to confirm TDS applicability.

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