For AY 2021-22, the assessee filed its return declaring total income of ₹23.93 crore and claimed TDS credit of ₹5.31 crore. The assessee sought credit for such TDS, asserting that the sister concerns had not claimed the benefit. Accordingly, it upheld the direction to allow TDS credit in the year of receipt and taxation of income. 250 of the Income Tax Act, 1961 (in short “the Act”) for Assessment Years (AYs) 2017-18, 2020-21, 2021-21, 2022-23 and 2024-25. The reliance placed on Rule 37BA is merely to demonstrate that in not all circumstances is TDS credit given to the deductee.