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The ITAT allowed the appeal of the assessee against the demand raised for short deduction of TDS under section 200A due to non-linking of PAN with Aadhar by the payee. The tribunal observed that the assessee deducted TDS at 1% based on the active status of the seller's PAN at the time of payment, unaware of its inactive status due to delayed PAN-Aadhar linking. Considering that the seller subsequently linked PAN with Aadhar, paid the applicable penalty, and disclosed the income from the transaction in the return, the tribunal emphasized the legislative intent to ensure compliance by the payee, not to penalize the payer for unintentional lapses. Further, the extended timeline for PAN-Aadhar linking supported the assessee's position. Consequently, the demand for short deduction of TDS at 19% was quashed, and the appeal was allowed.
The ITAT allowed the appeal of the assessee against the demand raised for short deduction of TDS under section 200A due to non-linking of PAN with Aadhar by the payee. The tribunal observed that the assessee deducted TDS at 1% based on the active status of the seller's PAN at the time of payment, unaware of its inactive status due to delayed PAN-Aadhar linking. Considering that the seller subsequently linked PAN with Aadhar, paid the applicable penalty, and disclosed the income from the transaction in the return, the tribunal emphasized the legislative intent to ensure compliance by the payee, not to penalize the payer for unintentional lapses. Further, the extended timeline for PAN-Aadhar linking supported the assessee's position. Consequently, the demand for short deduction of TDS at 19% was quashed, and the appeal was allowed.
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