No TDS Liability as Buyer’s Share Below ₹50 Lakh: ITAT Clarifies Section 194-IA Scope

ITO Vs Tarun Santramdas Varma (ITAT Ahmedabad) The ITAT Ahmedabad dismissed the Revenue’s appeal challenging the deletion of TDS demand under Section 194-IA for property purchases. The Tribunal upheld the CIT(A)’s findings that no TDS liability arose since each buyer’s payment to individual sellers was below ₹50 lakh, and the law applicable for A.Y. 2015-16 required consideration to be examined per buyer-seller transaction, not on an aggregate basis. It was also held that the Finance Act 2024 amendment introducing aggregation is prospective and not applicable retrospectively. Further, ...