In the case of Jerambhai Ratnabhai Patel v. Central Processing Unit (ITAT Ahmedabad, AY 2022-23, order dated 09.01.2026), the assessee sought TDS credit from the sale of property based on an unregistered family arrangement, claiming certain units “belonged” to him and reporting capital gains accordingly. However, the sale agreement and deed were in the names of his wife and son, with TDS deducted under their PANs.

The Tribunal ruled that since the family arrangement was unregistered and not included in the final sale agreement, and the assessee was not a confirming party with authority, the TDS credit could not be transferred to him. The Tribunal directed that TDS credit should be granted to the wife and son, pending verification. It also noted that they might need to revise or claim relief with approval under section 119(2)(b), while the assessee's entitlement to a refund was limited, resulting in the dismissal of the appeal.

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https://www.mytaxexpert.co.in/uploads/1769076347_JERAMBHAIRATNABHAIPATELAHMEDABADVS.CPCBANGALOREPRESENTJURISDICTIONTHEITOWARD512AHMEDABAD.pdf