Section 194IA(2) exemption limit applies to each transferee separately

Vinod Soni Vs ITO (ITAT Delhi) Conclusion: Limit of exemption of Rs. 50 lakh under section 194-IA(2) was applicable to each transferee separately as each transferee was a separate income tax entity therefore, the law has to be applied with reference to each transferee as an individual transferee / person and not with reference to the amount as per sale deed. Held: In the instant case, four persons of same family purchased 1/4thundivided equal shares in immovable property for Rs. 1,50,00,000/- and 1/4th share purchase consideration for each person was only Rs. 37,50,000/- each. AO held that si...