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Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Section 194-IA applies transferee-wise, so the threshold for TDS on purchase of immovable property must be examined with reference to each joint transferee's share of consideration. Where an assessee's individual share is below the statutory limit, tax deduction cannot be insisted on merely because the total consideration under a single sale deed exceeds that limit. The order treating the assessee as in default under section 200A, and the appellate order sustaining it, were therefore unsustainable and the demand was set aside.
Section 194-IA applies transferee-wise, so the threshold for TDS on purchase of immovable property must be examined with reference to each joint transferee's share of consideration. Where an assessee's individual share is below the statutory limit, tax deduction cannot be insisted on merely because the total consideration under a single sale deed exceeds that limit. The order treating the assessee as in default under section 200A, and the appellate order sustaining it, were therefore unsustainable and the demand was set aside.
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