SANCHIT GUPTA,RAMPUR vs. CIT A NFAC, DELHI

ITA 8431/DEL/2025Status: DisposedITAT Delhi21 May 2026AY 2024-259 pages
AI SummaryRemanded

What were the facts?

The assessee purchased property and deducted TDS at 1% as per Section 194IA. However, the seller's PAN was inoperative due to non-linking with Aadhaar, which mandated a higher TDS rate of 20% under Section 206AA read with Rule 114AAA(3). This resulted in a demand for short deduction of TDS and interest.

What did the Tribunal hold?

The Tribunal acknowledged the department's responsibility for not flagging inoperative PANs in its system. It directed the matter back to the AO for de novo determination, provided the seller declared the transaction and paid taxes. The Tribunal also suggested the revenue verify the seller's tax compliance.

What were the issues?

Whether the assessee (deductor) is liable for short deduction of TDS when the deductee's PAN was inoperative due to non-linking with Aadhaar, and if the department bears any responsibility for not flagging such inoperative PANs.

Which sections of the Income-tax Act were involved?

Section 194IA,Section 206AA,Section 200A,Section 139AA(2),Section 40(a)(ia),Section 201(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH‘G’: NEW DELHI

For Appellant: Shri K.V.S.R Krishna, CA and S. Aman Goel, CA
For Respondent: Shri Ravi Kant Choudhary
Hearing: 28.04.2026Pronounced: 21.05.2026

PER RAMIT KOCHAR, AM: This appeal in ITA No. 8431/Del/2025 for Assessment Year: 2024-25 has arisen from the learned CIT(A)’s appellate order passed u/s 250 of the Income-tax Act, 1961(hereinafter called “the Act”) dated 09.10.2025 in DIN & Order No: ITBA/NFAC/S/250/2025-26/1081600669(1), which in turn has arisen from order dated 29.08.2023 passed by learned DCIT, CPC, TDS u/s. 200A of the Act(Communication Reference No. TDS/2023/AK07943224/D/100001396470) .

2.

The assessee has raised following grounds of appeal in the memo of appeal filed with the Tribunal:

2 Sanchit Gupta v. CIT(A)

“1. That as per sec 206AA (1), the initial burden of the ass

The order continues below.

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