Finding the controversy to be no longer res integra, the Bench approved the assessment in entirety

The Tribunal observed that revenue has compared the figures reflected in the ST-3 returns and figures reflected in Form 26AS statement and raised the demand without further examining the reasons for the difference in the two statements.

The Court, however, rejected the Award Holder’s claim for interest on the deducted TDS, holding that such a direction would be inequitable since the amount had already been deposited with the Income Tax Department.