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    <title>2026 (4) TMI 1788 - DELHI HIGH COURT</title>
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    <description>Tax deducted at source on sale proceeds of immovable property sold under the SARFAESI framework was held refundable to the bank. Section 194IA applied to the deduction, but the bank did not become the owner of the secured asset; the borrower remained the owner and the bank acted only as a custodian of the sale proceeds. Since the income from the sale was not shown by the bank and its role was limited to recovery and accounting for surplus or deficit, the Revenue could not deny refund merely because the property sold did not belong to the bank. The bank&#039;s claim for refund was upheld.</description>
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    <pubDate>Tue, 21 Apr 2026 00:00:00 +0530</pubDate>
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      <title>2026 (4) TMI 1788 - DELHI HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=790719</link>
      <description>Tax deducted at source on sale proceeds of immovable property sold under the SARFAESI framework was held refundable to the bank. Section 194IA applied to the deduction, but the bank did not become the owner of the secured asset; the borrower remained the owner and the bank acted only as a custodian of the sale proceeds. Since the income from the sale was not shown by the bank and its role was limited to recovery and accounting for surplus or deficit, the Revenue could not deny refund merely because the property sold did not belong to the bank. The bank&#039;s claim for refund was upheld.</description>
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      <pubDate>Tue, 21 Apr 2026 00:00:00 +0530</pubDate>
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