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ITAT held that assessee was not liable for TDS default under Section 201(1)/201(1A) regarding immovable property transactions. For property purchased on 30.01.2018, where consideration paid to each of four co-owners was Rs. 40,25,000 (below Rs. 50 lakhs threshold), no TDS deduction was required under Section 194IA. The amended provision requiring aggregate consideration of all transferors applies only from 01.10.2024. Similarly, for property purchased on 30.08.2017 with consideration below Rs. 50 lakhs, stamp duty value consideration was not applicable before 01.04.2022. However, regarding audit fee payment, assessee was correctly treated as in default under Section 194J. Matter remanded to TDS AO for verification of recipient's tax payment and restricting interest computation from deduction date to recipient's return filing date. Demands under Section 201(1)/201(1A) for property transactions deleted.
ITAT held that assessee was not liable for TDS default under Section 201(1)/201(1A) regarding immovable property transactions. For property purchased on 30.01.2018, where consideration paid to each of four co-owners was Rs. 40,25,000 (below Rs. 50 lakhs threshold), no TDS deduction was required under Section 194IA. The amended provision requiring aggregate consideration of all transferors applies only from 01.10.2024. Similarly, for property purchased on 30.08.2017 with consideration below Rs. 50 lakhs, stamp duty value consideration was not applicable before 01.04.2022. However, regarding audit fee payment, assessee was correctly treated as in default under Section 194J. Matter remanded to TDS AO for verification of recipient's tax payment and restricting interest computation from deduction date to recipient's return filing date. Demands under Section 201(1)/201(1A) for property transactions deleted.
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