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The ITAT held that since the amounts paid to each transferor of land were individually below Rs. 50 lakhs, the provisions of section 194IA were not applicable. The amendment introducing an aggregate threshold under section 194IA(2) is effective only from 01.10.2024 and thus does not apply to AY 2015-16. Consequently, the assessee could not be held liable as an assessee-in-default under section 201(1) for failure to deduct TDS. The appeal was allowed, relieving the assessee from the default liability.
The ITAT held that since the amounts paid to each transferor of land were individually below Rs. 50 lakhs, the provisions of section 194IA were not applicable. The amendment introducing an aggregate threshold under section 194IA(2) is effective only from 01.10.2024 and thus does not apply to AY 2015-16. Consequently, the assessee could not be held liable as an assessee-in-default under section 201(1) for failure to deduct TDS. The appeal was allowed, relieving the assessee from the default liability.
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