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45. (2026) 1 (CTOTTJ 1692 (Delhi)
Sanchit Gupta v. DCIT
A.Y.: 2024-25
Date of Order: 21.05.2026
Sections: 194IA, 200A, 206AA
No liability to deduct TDS at higher rate prescribed in section 206AA can be cast on the deductor since the system did not red flag the PAN of the deductee as inoperative PAN and consequences of such inoperative PAN provided evidence is brought on record to establish that the seller of the property has reflected sale of property in his return and due taxes are paid.
FACTS
The assessee, along with two co-owners, purchased property during the year under consideration. The consideration paid/ payable by the assessee was Rs. 30,60,000. The assessee deducted and deposited income-tax at source (TDS) under section 194IA of Rs. 30,600 @ 1 per cent of the amount of consideration payable to the seller, vide Challan-cum-statement in Form No. 26QB dated 28th August, 2023. However, the PAN of the seller was not linked with Aadhar, rendering the PAN inoperative as per rule 114AAA(3), which in such cases mandates deduction of income tax at source at higher rate. Thu
