Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
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The Income Tax Appellate Tribunal held that the assessee had complied with the provisions of Section 194IA by deducting and depositing the requisite TDS at 1% on the purchase of property, as the recipient (seller) had furnished their PAN before completion of the transaction. The Tribunal opined that the higher TDS rate of 20% u/s 206AA for non-availability or non-quoting of PAN was not applicable in this case, as the legislative intent behind such provisions was to overcome issues in processing returns and granting TDS credit, which were not obstructed here. Consequently, the demand raised u/s 201(1) was vacated, and the issue of interest u/s 201(1A) and fee u/s 234E was restored to the Assessing Officer for recomputation in light of the Tribunal's observations.
The Income Tax Appellate Tribunal held that the assessee had complied with the provisions of Section 194IA by deducting and depositing the requisite TDS at 1% on the purchase of property, as the recipient (seller) had furnished their PAN before completion of the transaction. The Tribunal opined that the higher TDS rate of 20% u/s 206AA for non-availability or non-quoting of PAN was not applicable in this case, as the legislative intent behind such provisions was to overcome issues in processing returns and granting TDS credit, which were not obstructed here. Consequently, the demand raised u/s 201(1) was vacated, and the issue of interest u/s 201(1A) and fee u/s 234E was restored to the Assessing Officer for recomputation in light of the Tribunal's observations.
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