The assessee purchased property from two sellers, with payments to each being below Rs. 50 lakhs. The AO held the assessee liable for non-deduction of TDS under section 194IA. The Tribunal held that the threshold is to be examined per transferor-transferee basis. Since payments to each seller were below the limit, no TDS obligation arose and levy of interest was unjustified. (AY. 2015-16)
Archanaben Rajendrasingh Deval v. ITO (2025) 212 ITD 414 (Ahd)(Trib.)
S. 194IA : Deduction at source-Purchase of property-Two sellers-Consideration below Rs. 50 lakhs individually-No TDS liability-Interest deleted [S. 201(1)]