when the person deducting tds follows cash basis accounting system and person receiving tds certificate follows accrual method of accounting and the payment towards expenditure has been made after three years. should recipient claim tds certificate as it is not of the income of that year : CARYTHM@YAHOO.CO.IN
Although the case you have narrated a hypothetical one because revenue recognition model, today followed by most of the person , does not create such situation, but this type of anomaly may arise.As per the law, TDS is given credit in the year when income is shown. Since , the assessee has shown the income on the basis of mercantile basis, he can claim the credit in the year in which the TDS certificate is issued. If the A.O raises the point that the income is not belonging to that year , it is for him to pass rectification order suo moto or on your application.
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