154 petition disposal

I think in that case, it is deemed that the order is passed in the favour of ASSESSEE.

Please correct me if I am wrong.

Waiting for other expert's replies as well.

Thanks Sumit for your response. In fact I have learnt many points from You on various fronts.

No, not necessarily the order is in taxpayer's favour. The AO has granted less TDS credit though the same is available in 26AS and also claimed in the ITR. The assessee did not opt for appeal to CIT (A) as it is a mistake apparent from Record.

Regards,

It shall be deemed that AO has accepted the applicaiton & granted in favour of assessee. 

That is, the TDS credit shall be allowed now, after the expiry of the aforesaid 6 months.

But Sumit, if that be the case due to grant of TDS credit now after 6 months on a 'deeming' fiction there is an increase of refund than the amount of refund in the Order under 143(3). Naturally, the AO is not giving the balance Refund.

So, one cannot really conclude that he has acted on 154 petition and passed it on a deeming basis by allowing the differential TDS .

Any further thoughts.

Regards,