
Case Law Analysis
|Income Tax Appellate Tribunal
Higher TDS Rate Not Automatic When PAN-Aadhaar Linking Delay Is Beyond Deductor’s Control | Section 206AA (PAN Linking) : ITAT (Delhi G-Bench)
The ITAT ruled that a higher TDS rate under Section 206AA cannot be imposed automatically if the deductor’s delay in filing returns is caused by the deductees’ failure to link or activate PAN-Aadhaar, a circumstance beyond the deductor’s control. Such matters must be remitted to the Assessing Officer for fresh assessment, shielding compliant deductors from unwarranted penalties. The decision benefits taxpayers who face third-party PAN linking delays.