Case Name : Stallion securities ltd. V. Ito
Citation :  91 itd 338 (hyd. – Trib.)
Court : Itat-hyderabad
Section : 194 to 206c
Meaning : The words ‘assessable’ and ‘assessed’ are not synonymous with each other. The word ‘assessable’ speaks of the legal position in which an income has to be brought to tax, whereas the word ‘assessed’ speaks of the factual position in which the income is assessed to tax. Since the legislature has guardedly used the word ‘assessable’, it is the duty of the courts to assign proper meaning to that word in which event the credit for tds amount has to be given only in the year in which the dividend income is assessable and not in the year in which the dividend income was actually assessed to tax.