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ITAT reversed the CIT(A) and AO's determination that appellant was an assessee-in-default under s.201(1) for failure to deduct TDS under s.194IA. The Tribunal held that since payments to individual sellers (21,83,680 and 31,83,680) were each below the 50,00,000 threshold, s.194IA provisions were not applicable, following Bhikhabhai H. Patel. The CIT(A) failed to address the legal issues raised by appellant or examine the transaction structure in light of judicial precedent. Consequently, the demand under s.201(1) and interest under s.201(1A) were deleted, rendering moot the remaining grounds concerning s.2(14)(iii), proviso to s.201(1), Explanation to s.191, and penalty under s.271C.
ITAT reversed the CIT(A) and AO's determination that appellant was an assessee-in-default under s.201(1) for failure to deduct TDS under s.194IA. The Tribunal held that since payments to individual sellers (21,83,680 and 31,83,680) were each below the 50,00,000 threshold, s.194IA provisions were not applicable, following Bhikhabhai H. Patel. The CIT(A) failed to address the legal issues raised by appellant or examine the transaction structure in light of judicial precedent. Consequently, the demand under s.201(1) and interest under s.201(1A) were deleted, rendering moot the remaining grounds concerning s.2(14)(iii), proviso to s.201(1), Explanation to s.191, and penalty under s.271C.
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