Manoj Kumar Vs ITO (ITAT Delhi)
Summary: The Delhi Bench of the Income Tax Appellate Tribunal dealt with three appeals filed by the assessee, Manoj Kumar, Proprietor of M/s Manoj Metals, for Assessment Year 2024-25 against the order of the CIT(A)-7, Mumbai dated 14.08.2025. The proceedings arose from an order dated 06.02.2025 passed under section 154 read with sections 200A/206CB of the Income Tax Act, 1961 by CPC-TDS. The dispute concerned deduction of tax at the normal rate on transactions where the PANs of the deductees had not been linked with Aadhaar and were consequently inoperative. The Department applied the higher TDS rate, besides charging fee for late filing under section 234E and interest under sections 201(1A) and 220(2). The Assessing Officer computed a total demand of Rs.48,07,910/-.
The assessee contended that the failure to link PAN with Aadhaar was attributable to the deductees and that the assessee had deducted TDS at the otherwise applicable rate. In the grounds of appeal, the assessee asserted that delay in filing TDS returns occurred because suppliers had not timely linked and activated their PANs, that the delay was bona fide and beyond the assessee’s control, and that the assessee had acted on suppliers’ assurances. In relation to purchases, the assessee stated that tax had been deducted at 0.1% under Section 194Q. The assessee also challenged the application of the higher rate under Section 206AA and relied upon CBDT relaxations concerning PAN-Aadhaar linkage.
