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 1/4^thundivided equal shares in immovab

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