Interest for TDS Default levied on Buyer of Property even if NRI Seller Already Paid Taxes in his Return

Sh. Harpal Singh Vs DCIT (ITAT Chandigarh) The issue under consideration is whether interest u/s 201(1A) will be levied on assessee even if NRI seller had already paid taxes as per his return? ITAT states that, there are two persons under the Act liable to pay interest on tax on the same income. The legislature would not have contemplated such a situation where in respect of the tax on interest income, two persons are liable to pay interest for the delayed payment of tax. We are, therefore, inclined to hold that whatever there is a possibility of a deduction of tax at source, the person who ha...