The exemption of Rs. 50 lakh in s. 194-IA(2) is applicable w.r.t. the amount related to each transferee and not with reference to the amount as per sale deed. Each transferee is a separate income tax entity and the law has to be applied with reference to each transferee as an individual transferee / person – ITAT Delhi
ITAT Delhi in the judgement of Vinod Soni Vs. ITO TDS Faridabad in ITA No. 2736/Del/2015 held the following: Section 194-IA(2) provides that Section 194-IA(1)...