CPC has raised a short-deduction demand on me because my payee's PAN was inoperative for want of Aadhaar linking. What exactly does an inoperative PAN do, and is there any Board relief?
An inoperative PAN carries four consequences and only four, and rule 114AAA(3) lists them: no refund of tax is made, no interest is payable on that refund for the period, tax deductible under Chapter XVII-B is deducted at the higher rate under section 206AA, and tax collectible under Chapter XVII-BB is collected at the higher rate under section 206CC. The third and fourth of those fall on the DEDUCTOR or COLLECTOR, not on the person who failed to link, which is why the demand lands on someone who did nothing wrong. The Board has issued a sequence of circulars relieving the deductor where the PAN is made operative by a date, and the sequence — Circular No. 3/2023 dated 28 March 2023, Circular No. 6/2024 dated 23 April 2024 and Circular No. 9/2025 dated 21 July 2025 — is the first thing to check, before any argument on merits.
Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2023-07-01, reported as Income-tax Act 1961, s.139AA(2) proviso; Income-tax Rules 1962, rule 114AAA, substituted by the Income-tax (Fourth Amendment) Rules 2023 with effect from 1 April 2023 (the department's own footnote on the rule page), the substituting instrument being Notification No. 15 of 2023 dated 28 March 2023 as recited in CBDT Circular No. 6/2024; consequences effective from 1 July 2023 as specified by the Board under rule 114AAA(4). It bears on section 139AA, section 139AA(2), section 206AA, section 206CC, section 194Q, section 194-O, section 194-IA, section 200A, section 206CB, section 119(2)(b) of the Income Tax Act 1961, in TDS Defaults, Refunds, Interest & Condonation, Demand, Recovery & Stay and How Tax Law Is Read matters.
This is now the single commonest automated demand in the system, and almost every element of it is counter-intuitive. First, the trigger is not the deductor's default at all: rule 114AAA(1) makes the PAN inoperative because the HOLDER failed to intimate his Aadhaar number by 31 March 2022, and the deductor has no means of compelling him. Second, the consequences do not run from the date the PAN went inoperative: sub-rule (4) says they have effect 'from the date specified by the Board', and the Board specified 1 July 2023, so a transaction before that date should not attract the higher rate at all. Third, the relief is by circular, not by statute, so it is keyed to dates and nothing else — the window is the whole argument. Fourth, the higher rate is not always twenty per cent: section 206AA(1) prescribes the higher of the rate in the relevant section, the rate in force, or twenty per cent, but the two provisos cut that to five per cent where the deduction is under section 194-O or section 194Q. A purchaser under section 194Q deducting 0.1 per cent therefore faces 5 per cent, not 20 — a fifty-fold multiplier on a large turnover, which is how these demands reach a crore. Fifth, rule 114AAA(2) gives the taxpayer no instant cure: once the fee under rule 114(5A) is paid, the PAN becomes operative 'within thirty days from the date of intimation', so a deductor who discovers the problem on the last day of a quarter cannot fix it in time. Note finally what is NOT on the list in sub-rule (3): the PAN does not become invalid, the return is not treated as unfiled, and nothing in the rule disallows the payee's own TDS credit. The 2017 text of the proviso to section 139AA(2), which deemed the PAN 'invalid', was replaced; anyone advising off the older wording is advising off a repealed text.
Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.
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Section 139AA(2) requires every person allotted a permanent account number as on 1 July 2017 who is eligible to obtain an Aadhaar number to intimate that number on or before a date notified in the Official Gazette, and its proviso provides that on failure to intimate, the permanent account number 'shall be made inoperative after the date so notified in such manner as may be prescribed'. Rule 114AAA prescribes that manner. Sub-rule (1) fixes the failure date at 31 March 2022 and provides that the permanent account number of a person who has not intimated by then becomes inoperative and that he is liable to the fee under rule 114(5A). Sub-rule (2) provides that where he intimates his Aadhaar number after 31 March 2022, after paying that fee, his permanent account number becomes operative within thirty days from the date of intimation. Sub-rule (3) sets out the consequences for the period from the date specified under sub-rule (4) until the number becomes operative: refund of any amount of tax or part of it due under the Act shall not be made; interest shall not be payable on such refund for that period; where tax is deductible under Chapter XVII-B in the case of such person, it shall be deducted at the higher rate in accordance with section 206AA; and where tax is collectible at source under Chapter XVII-BB, it shall be collected at the higher rate in accordance with section 206CC. Sub-rule (4) provides that sub-rule (3) shall have effect from the date specified by the Board, and sub-rule (5) leaves the formats, standards and verification procedure to the Principal Director General or Director General of Income-tax (Systems). Section 206AA(1) requires the deductee to furnish his permanent account number, failing which tax is deducted at the higher of the rate specified in the relevant provision, the rates in force, or twenty per cent, with a first proviso substituting five per cent for twenty where the deduction is under section 194-O and a second proviso doing the same where it is under section 194Q. By Circular No. 3 of 2023 dated 28 March 2023 the Board specified under rule 114AAA(4) that the consequences take effect from 1 July 2023 and continue until the permanent account number becomes operative. By Circular No. 6 of 2024 dated 23 April 2024, issued in partial modification and continuation of Circular No. 3 of 2023 after grievances from deductors and collectors receiving short-deduction notices, the Board specified that for transactions entered into up to 31 March 2024, and where the permanent account number becomes operative on or before 31 May 2024, there shall be no liability on the deductor or collector to deduct or collect tax under section 206AA or section 206CC, the deduction or collection mandated by the other provisions of Chapter XVII-B or XVII-BB being applicable instead. By Circular No. 9 of 2025 dated 21 July 2025 the Board extended that relief to transactions entered into between 1 April 2024 and 31 July 2025 where the permanent account number is made operative on or before 30 September 2025, and provided that where the amount is paid or credited on or after 1 August 2025 there is no such liability if the permanent account number is made operative within two months from the end of the month in which the amount is paid or credited.
Statutory position — no holding is asserted; this entry reproduces statutory and subordinate legislative text and the Board's circulars as recited in judgments that reproduce them. An inoperative permanent account number produces the four consequences listed in rule 114AAA(3) and no others, two of which operate against the deductor or collector rather than against the person who failed to link. Those consequences run only from the date specified by the Board under sub-rule (4), which is 1 July 2023. Relief for the deductor or collector is available in the three date windows created by Circular No. 6/2024 and Circular No. 9/2025, the last of which is an ongoing two-month cure period for amounts paid or credited on or after 1 August 2025.
The architecture is worth following because it explains why the demand lands where it does. Section 139AA(2) imposes the obligation on the PAN HOLDER and its proviso attaches a consequence to his PAN, not to anybody else. Rule 114AAA then translates 'inoperative' into a list, and two items on that list — sub-rules (3)(iii) and (3)(iv) — are not consequences for the holder at all but instructions about how a third party must deduct or collect. Section 206AA and section 206CC are the operative provisions those two items point to, and both are addressed to the deductor and collector, who bear the shortfall under section 200A or section 206CB processing. The rule contains no knowledge requirement and no defence, which is why the Board had to act by circular: paragraph 3 of Circular No. 6/2024 records in terms that grievances were received from taxpayers receiving notices of short deduction or collection 'while carrying out the transactions where the PANs of the deductees/collectees were inoperative'. The relief the Board gave is not a waiver of the higher rate on hardship grounds; it is a conditional disapplication keyed to the PAN being made operative by a stated date, with the ordinary Chapter XVII-B or XVII-BB rate applying instead. That structure has two consequences for argument: inside a window there is nothing to argue about, and outside one there is nothing in the circulars to argue with.
(3) A person, whose permanent account number has become inoperative, shall be liable for further consequences for the period commencing from the date as specified under sub-rule (4) till the date it becomes operative, namely:— (i) refund of any amount of tax or part thereof, due under the provisions of the Act shall not be made; (ii) interest shall not be payable on such refund for the period, beginning with the date specified under sub-rule (4) and ending with the date on which it becomes operative; (iii) where tax is deductible under Chapter XVIIB in case of such person, such tax shall be deducted at higher rate, in accordance with provisions of section 206AA; (iv) where tax is collectible at source under Chapter XVIIBB in case of such person, such tax shall be collected at higher rate, in accordance with provisions of section 206CC.
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Handle my notice → Ask a CA on WhatsAppAn inoperative PAN carries four consequences and only four, and rule 114AAA(3) lists them: no refund of tax is made, no interest is payable on that refund for the period, tax deductible under Chapter XVII-B is deducted at the higher rate under section 206AA, and tax collectible under Chapter XVII-BB is collected at the higher rate under section 206CC. The third and fourth of those fall on the DEDUCTOR or COLLECTOR, not on the person who failed to link, which is why the demand lands on someone who did nothing wrong. The Board has issued a sequence of circulars relieving the deductor where the PAN is made operative by a date, and the sequence — Circular No. 3/2023 dated 28 March 2023, Circular No. 6/2024 dated 23 April 2024 and Circular No. 9/2025 dated 21 July 2025 — is the first thing to check, before any argument on merits. This was decided by the CBDT Circulars & Instructions (Not applicable — statutory text) and bears on section 139AA, section 139AA(2), section 206AA, section 206CC, section 194Q, section 194-O, section 194-IA, section 200A, section 206CB, section 119(2)(b) of the Income Tax Act 1961. It is reported as Income-tax Act 1961, s.139AA(2) proviso; Income-tax Rules 1962, rule 114AAA, substituted by the Income-tax (Fourth Amendment) Rules 2023 with effect from 1 April 2023 (the department's own footnote on the rule page), the substituting instrument being Notification No. 15 of 2023 dated 28 March 2023 as recited in CBDT Circular No. 6/2024; consequences effective from 1 July 2023 as specified by the Board under rule 114AAA(4). This is now the single commonest automated demand in the system, and almost every element of it is counter-intuitive. First, the trigger is not the deductor's default at all: rule 114AAA(1) makes the PAN inoperative because the HOLDER failed to intimate his Aadhaar number by 31 March 2022, and the deductor has no means of compelling him. Second, the consequences do not run from the date the PAN went inoperative: sub-rule (4) says they have effect 'from the date specified by the Board', and the Board specified 1 July 2023, so a transaction before that date should not attract the higher rate at all. Third, the relief is by circular, not by statute, so it is keyed to dates and nothing else — the window is the whole argument. Fourth, the higher rate is not always twenty per cent: section 206AA(1) prescribes the higher of the rate in the relevant section, the rate in force, or twenty per cent, but the two provisos cut that to five per cent where the deduction is under section 194-O or section 194Q. A purchaser under section 194Q deducting 0.1 per cent therefore faces 5 per cent, not 20 — a fifty-fold multiplier on a large turnover, which is how these demands reach a crore. Fifth, rule 114AAA(2) gives the taxpayer no instant cure: once the fee under rule 114(5A) is paid, the PAN becomes operative 'within thirty days from the date of intimation', so a deductor who discovers the problem on the last day of a quarter cannot fix it in time. Note finally what is NOT on the list in sub-rule (3): the PAN does not become invalid, the return is not treated as unfiled, and nothing in the rule disallows the payee's own TDS credit. The 2017 text of the proviso to section 139AA(2), which deemed the PAN 'invalid', was replaced; anyone advising off the older wording is advising off a repealed text. If it applies to you, the first step is this: Fix your transaction date first and map it to the circular windows before arguing anything else: for transactions up to 31 March 2024, the PAN must have become operative on or before 31 May 2024 (Circular No. 6/2024); for transactions between 1 April 2024 and 31 July 2025, on or before 30 September 2025; and for an amount paid or credited on or after 1 August 2025, within two months from the end of the month of payment or credit (Circular No. 9/2025).
Section 139AA(2) requires every person allotted a permanent account number as on 1 July 2017 who is eligible to obtain an Aadhaar number to intimate that number on or before a date notified in the Official Gazette, and its proviso provides that on failure to intimate, the permanent account number 'shall be made inoperative after the date so notified in such manner as may be prescribed'. Rule 114AAA prescribes that manner. Sub-rule (1) fixes the failure date at 31 March 2022 and provides that the permanent account number of a person who has not intimated by then becomes inoperative and that he is liable to the fee under rule 114(5A). Sub-rule (2) provides that where he intimates his Aadhaar number after 31 March 2022, after paying that fee, his permanent account number becomes operative within thirty days from the date of intimation. Sub-rule (3) sets out the consequences for the period from the date specified under sub-rule (4) until the number becomes operative: refund of any amount of tax or part of it due under the Act shall not be made; interest shall not be payable on such refund for that period; where tax is deductible under Chapter XVII-B in the case of such person, it shall be deducted at the higher rate in accordance with section 206AA; and where tax is collectible at source under Chapter XVII-BB, it shall be collected at the higher rate in accordance with section 206CC. Sub-rule (4) provides that sub-rule (3) shall have effect from the date specified by the Board, and sub-rule (5) leaves the formats, standards and verification procedure to the Principal Director General or Director General of Income-tax (Systems). Section 206AA(1) requires the deductee to furnish his permanent account number, failing which tax is deducted at the higher of the rate specified in the relevant provision, the rates in force, or twenty per cent, with a first proviso substituting five per cent for twenty where the deduction is under section 194-O and a second proviso doing the same where it is under section 194Q. By Circular No. 3 of 2023 dated 28 March 2023 the Board specified under rule 114AAA(4) that the consequences take effect from 1 July 2023 and continue until the permanent account number becomes operative. By Circular No. 6 of 2024 dated 23 April 2024, issued in partial modification and continuation of Circular No. 3 of 2023 after grievances from deductors and collectors receiving short-deduction notices, the Board specified that for transactions entered into up to 31 March 2024, and where the permanent account number becomes operative on or before 31 May 2024, there shall be no liability on the deductor or collector to deduct or collect tax under section 206AA or section 206CC, the deduction or collection mandated by the other provisions of Chapter XVII-B or XVII-BB being applicable instead. By Circular No. 9 of 2025 dated 21 July 2025 the Board extended that relief to transactions entered into between 1 April 2024 and 31 July 2025 where the permanent account number is made operative on or before 30 September 2025, and provided that where the amount is paid or credited on or after 1 August 2025 there is no such liability if the permanent account number is made operative within two months from the end of the month in which the amount is paid or credited. The matter was decided on 2023-07-01 by the CBDT Circulars & Instructions (Not applicable — statutory text). On those facts the CBDT Circulars & Instructions held as follows. Statutory position — no holding is asserted; this entry reproduces statutory and subordinate legislative text and the Board's circulars as recited in judgments that reproduce them. An inoperative permanent account number produces the four consequences listed in rule 114AAA(3) and no others, two of which operate against the deductor or collector rather than against the person who failed to link. Those consequences run only from the date specified by the Board under sub-rule (4), which is 1 July 2023. Relief for the deductor or collector is available in the three date windows created by Circular No. 6/2024 and Circular No. 9/2025, the last of which is an ongoing two-month cure period for amounts paid or credited on or after 1 August 2025.
The architecture is worth following because it explains why the demand lands where it does. Section 139AA(2) imposes the obligation on the PAN HOLDER and its proviso attaches a consequence to his PAN, not to anybody else. Rule 114AAA then translates 'inoperative' into a list, and two items on that list — sub-rules (3)(iii) and (3)(iv) — are not consequences for the holder at all but instructions about how a third party must deduct or collect. Section 206AA and section 206CC are the operative provisions those two items point to, and both are addressed to the deductor and collector, who bear the shortfall under section 200A or section 206CB processing. The rule contains no knowledge requirement and no defence, which is why the Board had to act by circular: paragraph 3 of Circular No. 6/2024 records in terms that grievances were received from taxpayers receiving notices of short deduction or collection 'while carrying out the transactions where the PANs of the deductees/collectees were inoperative'. The relief the Board gave is not a waiver of the higher rate on hardship grounds; it is a conditional disapplication keyed to the PAN being made operative by a stated date, with the ordinary Chapter XVII-B or XVII-BB rate applying instead. That structure has two consequences for argument: inside a window there is nothing to argue about, and outside one there is nothing in the circulars to argue with. In the words reproduced by the source cited on this page: "(3) A person, whose permanent account number has become inoperative, shall be liable for further consequences for the period commencing from the date as specified under sub-rule (4) till the date it becomes operative, namely:— (i) refund of any amount of tax or part thereof, due under the provisions of the Act shall not be made; (ii) interest shall not be payable on such refund for the period, beginning with the date specified under sub-rule (4) and ending with the date on which it becomes operative; (iii) where tax is deductible under Chapter XVIIB in case of such person, such tax shall be deducted at higher rate, in accordance with provisions of section 206AA; (iv) where tax is collectible at source under Chapter XVIIBB in case of such person, such tax shall be collected at higher rate, in accordance with provisions of section 206CC."
It was decided by the CBDT Circulars & Instructions on 2023-07-01 and is reported as Income-tax Act 1961, s.139AA(2) proviso; Income-tax Rules 1962, rule 114AAA, substituted by the Income-tax (Fourth Amendment) Rules 2023 with effect from 1 April 2023 (the department's own footnote on the rule page), the substituting instrument being Notification No. 15 of 2023 dated 28 March 2023 as recited in CBDT Circular No. 6/2024; consequences effective from 1 July 2023 as specified by the Board under rule 114AAA(4). Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them. A CBDT circular or instruction binds officers of the department but not the assessee and not the courts. Where a circular helps you, you may hold the department to it. Where it hurts you, it cannot override the Act or a judgment. On section 139AA, section 139AA(2), section 206AA, section 206CC, section 194Q, section 194-O, section 194-IA, section 200A, section 206CB, section 119(2)(b), the practical question is whether the facts of your own notice match the facts of this case closely enough for the same rule to apply.
It cuts both ways and is cited by both sides. Statutory position — no holding is asserted; this entry reproduces statutory and subordinate legislative text and the Board's circulars as recited in judgments that reproduce them. An inoperative permanent account number produces the four consequences listed in rule 114AAA(3) and no others, two of which operate against the deductor or collector rather than against the person who failed to link. Those consequences run only from the date specified by the Board under sub-rule (4), which is 1 July 2023. Relief for the deductor or collector is available in the three date windows created by Circular No. 6/2024 and Circular No. 9/2025, the last of which is an ongoing two-month cure period for amounts paid or credited on or after 1 August 2025. It arises in TDS Defaults, Refunds, Interest & Condonation, Demand, Recovery & Stay and How Tax Law Is Read matters, on section 139AA, section 139AA(2), section 206AA, section 206CC, section 194Q, section 194-O, section 194-IA, section 200A, section 206CB, section 119(2)(b) of the Income Tax Act 1961, and was decided by Not applicable — statutory text. Before relying on it, read the source linked on this page and check whether it has since been distinguished, overruled or overtaken by an amendment to the Income Tax Act. In practice the steps that follow from it are these. For any transaction before 1 July 2023, take the point that rule 114AAA(4) makes the sub-rule (3) consequences effective only 'from the date specified by the Board', and the Board specified 1 July 2023 in Circular No. 3/2023. Check which rate the department has actually applied. Under section 194-O or section 194Q the provisos to section 206AA(1) substitute five per cent for twenty; a CPC computation at twenty per cent on a section 194Q payment is simply wrong on the face of it. Verify the deductee's PAN status on the department's portal before every payment and keep the screenshot with the voucher — the Delhi Bench in Sanchit Gupta v. DCIT (CPC), TDS (21 May 2026), already in this library, records that the onus is placed on the deductor to ensure that the deductee's PAN is not inoperative. Build the standing process around the 1 August 2025 limb of Circular No. 9/2025: it is not a one-off amnesty but an ongoing two-month cure period, so a deductor who chases the payee within two months of the month-end is protected. Do not concede that an inoperative PAN affects the payee's refund of the SAME tax you deducted in a different way — sub-rule (3)(i) and (ii) bar the refund and the interest on it, but they are consequences for the PAN holder, not for you. If you are outside every window, the remaining routes are an application under section 119(2)(b) for condonation and the argument that the payee has returned the income and paid the tax; neither is in the rule, and both are discretionary.
Still good law. This is the rule and the circulars themselves, not a decision about them. Rule 114AAA was read in full from the department's own rule page, which carries no year stamp; the section 139AA text was read from four departmental pages stamped 2019 (No. 2), 2020, 2021 and 2022, all identical, and independently from the reproduction of section 139AA(2) inside the ITAT Delhi order in Manoj Kumar dated 31 August 2026. Because no departmental page for section 139AA carrying a stamp later than 2022 could be located, a subsequent amendment to that section cannot be excluded. The circulars were not retrieved in their own PDFs — see the editor note — and are stated from the full text of Circular No. 6/2024 reproduced in the Madras High Court judgment of 6 September 2024 and from the recital of Circulars 3/2023 and 9/2025 in the ITAT Delhi orders in Sanchit Gupta (21 May 2026) and Manoj Kumar (31 August 2026). Whether the Board has issued any circular AFTER Circular No. 9/2025 of 21 July 2025 could not be established on this pass: the department's circulars listing page renders no rows and the session's web-search budget was exhausted, so a later circular may exist and has not been ruled out. No source could be cited for that finding. Checking whether an authority still stands matters as much as knowing what it held: a decision may be overruled on one point and survive on another, or the provision it interprets may have been amended since. Read the source and the editor's note on this page before relying on it in a reply to an Assessing Officer or in an appeal.
This is a statutory entry, not a decided case. The 'tier' value 'cbdt' is used because the library's fixed tier vocabulary has no value for a statutory entry, and 'bench' accordingly reads 'Not applicable — statutory text'; 'favours' is null because a statutory entry states the text and takes no side. The date in 'decided_on', 1 July 2023, is the COMMENCEMENT DATE of the rule 114AAA(3) consequences as specified by the Board under sub-rule (4), not a decision date. Sourcing, precisely. (1) Rule 114AAA was read in full from the department's own rule page https://www.incometaxindia.gov.in/w/rule-114aaa. Departmental RULE pages carry no 'Year:' stamp at all — this one printed none — so the rule cannot be dated the way a section can, and I do not claim to have dated it. The rule page does, however, print an amendment note at its foot — 'Substituted by the IT (Fourth Amdt.) Rules, 2023, w.e.f. 1-4-2023' — which names the substituting instrument and its date of effect independently of the circular's recital of Notification No. 15 of 2023; the page carries the Income Tax Department's own copyright line and no other. (2) Section 139AA was read from five departmental section pages, stamped Year 2017, Year 2019 (No. 2), Year 2020, Year 2021 and Year 2022. All of them except the 2017 page print the identical proviso to sub-section (2) — 'the permanent account number allotted to the person shall be made inoperative after the date so notified in such manner as may be prescribed' — while the 2017 page prints the superseded wording 'shall be deemed to be invalid'. No page carrying a stamp later than 2022 was located for this section: I probed suffixes -62 and -63, both 404. The text is therefore stated from archived pages that agree with each other from 2019 onwards, and independently from the reproduction of section 139AA(2) inside the ITAT Delhi order in Manoj Kumar (ITA Nos. 1499 to 1501/Del/2026, 31 August 2026), which sets out the same proviso and records that the notified date was 31 March 2022. A later amendment cannot be excluded. (3) The circulars. I could not retrieve any CBDT circular PDF from incometaxindia.gov.in on this pass — /communications/circular/ and /news/ paths for circulars 6/2024 and 9/2025 all returned HTTP 404, the circulars listing page renders no rows, and WebSearch was exhausted for this session so the working URL could not be found. What this entry says about the circulars comes from two judicial sources that reproduce or recite them: the Madras High Court in Srirangapattinam Desigan Srinivasan v. DCIT (CPC-TDS), W.P. No. 1457 of 2024, decided 6 September 2024, sets out Circular No. 6/2024, F. No. 275/4/2024-IT(B), dated 23 April 2024 IN FULL, including its recitation of Circular No. 3 of 2023 dated 28 March 2023 and the statement that the consequences 'shall take effect from 1st July, 2023 and continue till the PAN becomes operative'; and the ITAT Delhi order in Manoj Kumar recites Circular No. 9/2025 dated 21 July 2025 with its two limbs. Two oddities in the Madras judgment should be known: at para 2.1 counsel's submission is recorded as referring to 'Circular No.3 of 2023 dated 23.04.2024', which conflates the two circulars, while the Court itself gets it right at para 5.1 as 'Circular No.6 of 2024, dated 23.04.2024'; and the reproduced circular text as printed refers to 'section 139AAA of the Income-tax Act, 1961', which is a transcription slip for section 139AA. (4) Section 206AA, including both provisos and sub-section (7), was read from departmental pages stamped Year 2022, Year 2023, Year 2024 (No. 1), Year 2024 (No. 2) and Year 2025, all printing identical text; the Year 2024 (No. 1) page carries footnote 72, 'Inserted by the Finance Act, 2021, w.e.f. 1-7-2021', against the section 194Q proviso. (5) Rule 114(5A), which prescribes the fee, was NOT retrieved on this pass; the reference to it here is the reference rule 114AAA itself makes, and the amount of that fee is not stated. No indiankanoon bare-act page was used for any part of this entry. This library shows the verification state of every entry openly. This entry has not yet been read in full by a chartered accountant. The summary reflects the sources listed on this page. Read the source before you rely on it in a reply to an Assessing Officer or in an appeal before the Commissioner (Appeals) or the Income Tax Appellate Tribunal.
Statutory position — no holding is asserted; this entry reproduces statutory and subordinate legislative text and the Board's circulars as recited in judgments that reproduce them. An inoperative permanent account number produces the four consequences listed in rule 114AAA(3) and no others, two of which operate against the deductor or collector rather than against the person who failed to link. Those consequences run only from the date specified by the Board under sub-rule (4), which is 1 July 2023. Relief for the deductor or collector is available in the three date windows created by Circular No. 6/2024 and Circular No. 9/2025, the last of which is an ongoing two-month cure period for amounts paid or credited on or after 1 August 2025.
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