The Tribunal dismissed the assessee’s appeal, holding that the assessee was rightfully treated as an “assessee-in-default” under Section 201(1) for failure to deduct TDS on property purchases as required under Section 194IA. The assessee claimed relief under the First Proviso to Section 201(1), arguing that the property sellers had already discharged their tax liability. However, the assessee failed to furnish Form 26A or a CA certificate as prescribed under Rule 31ACB of the Income Tax Rules, which is necessary to avail of the Proviso. The Tribunal further upheld the levy of interest under Section 201(1A), relying on the CBDT Circular No. 275/201/95-IT(B) dated 29.01.1997 and the Supreme Court’s decision in  Hindustan Coca Cola Beverage Pvt. Ltd. vs. CIT (2007) 163 taxmann.com 355 (SC), holding that interest is payable by the purchaser until the seller files their tax returns. As the assessee did not prove compliance with these provisions, the interest demand was confirmed. Both appeals were dismissed as the assessee could not substantiate claims or comply with the procedural requirements. (AY. 2015-16)