TDS on joint property purchase depends on the assessee's individual share meeting the statutory threshold, not the total consideration.

In a joint purchase of immovable property, the obligation to deduct tax at source under section 194IA(1) did not arise where the assessee's individual share in the consideration was below the statutory threshold, even though the total purchase price exceeded that limit. On that factual basis, the assessee could not be treated as an assessee in default under section 201(1) or held liable for interest under section 201(1A) of the Income-tax Act, 1961. The analysis turns on the assessee's share-wise exposure to the threshold, not on the total transaction value alone.

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Issues: Whether the assessee, having purchased an immovable property in joint ownership and having a share below the statutory threshold, was obliged to deduct tax at source under section 194IA(1) of the Income-tax Act, 1961, and consequently liable to be treated as an assessee in default under section 201(1) and section 201(1A).

Analysis: The property was purchased jointly for a total consideration exceeding the monetary threshold, but the assessee's individual share was below the prescribed limit. On that factual footing, the statutory obligation to deduct tax at source was held not to arise against the assessee in respect of his share.

Conclusion: The assessee was not liable to deduct tax at source and could not be treated as an assessee in default under section 201(1) and section 201(1A) of the Income-tax Act, 1961.

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