TDS on agricultural land transfers cannot arise through enhanced PAN-based rates where the primary deduction provision is inapplicable.

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....Tax deduction on transfer of agricultural land under section 194-IA does not arise unless the land falls within that provision's scope. The text states that a registered sale deed identified the property as agricultural land and no contrary material established that it was covered land; therefore, no primary TDS obligation applied. Section 206AA only increases the deduction rate where tax is otherwise deductible and PAN is not furnished; it cannot independently create a TDS liability. Consequently, section 201(1) cannot treat the purchaser as an assessee in default absent a statutory duty to deduct. The short-deduction demand and consequential interest were deleted.....