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Tds on payment to NRI on sale of property


17 September 2024 assessee has purchased a property from NRI of 6 cr & deducts a tds @ 23.92% I. e. Rs. 14352000. however Cpc calculates a tds of Rs. 15600000 & sends the assessee a short deduction notice of Rs. 12.48 lacs.
Assessee write a mail to tds cpc. where they replied that nature of remittance mentioned in statement is not covered under DTAA hence short deduction default has been raised. you are requested to pay the demand.
Is this reply correct?
we have deducted a tds as per income tax Act & not as per DTAA.
please reply



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