RASHMI SINGH,JAIPUR vs. ITO, TDS-2, JAIPUR

ITA 694/JPR/2026Status: DisposedITAT Jaipur25 August 2026AY 2019-206 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the failure to file Form 26A electronically was a procedural lapse, especially since the seller had discharged their tax liability. Therefore, the assessee was entitled to protection under the proviso to Section 201(1).

What were the facts?

The assessee purchased an immovable property and failed to deduct TDS as required by Section 194-IA. The assessee filed Form 26A manually, but the AO treated the assessee as being in default and levied tax and interest.

What were the issues?

Whether a procedural lapse in filing Form 26A electronically, when the tax liability is discharged, can lead to treating the assessee as in default under Section 201(1) and levying interest under Section 201(1A).

Which sections of the Income-tax Act were involved?

Section 194-IA,Section 201(1),Section 201(1A),Section 271C

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, JAIPUR “SMC” BENCH, JAIPUR

Before: SMT. ANNAPURNA GUPTA & SHRI KULDIP SINGH

PER : KULDIP SINGH, JUDICIAL MEMBER:-

Appellant, Rashmi Singh by filing the present appeal, sought to set aside the impugned order (dated 12.02.2026) passed by Commissioner of Income Tax (Appeals)-3, Mumbai [hereinafter referred to as the ‘CIT(A)’] on the grounds interalia that :- 1. The impugned order passed u/s 201(1)/201(1A) dated 30-03-2025 is bad in law; for want of juri iction, against the principle of natural justice and various other statutory reasons and hence same kindly be quashed.

I.T.A No. 694/JPR/2026 Page No 2 Rashmi Singh

2.

The action of Id. AO in taking action u/s 201(1)/201(1A) is bad in law and without juri iction. Conseq

The order continues below.

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