Tax deduction at source on external development charges rejected where binding High Court precedent covered the issue.

External development charges were held not subject to tax deduction at source, because the jurisdictional High Court had already decided the issue in the assessee's favour in connected matters. As no distinguishing factual feature or contrary Supreme Court ruling was shown, the Revenue's challenge was found unsustainable and the assessee prevailed.

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Issues: Whether the assessee was liable to deduct tax at source on external development charges.

Analysis: The issue had already been decided in the assessee's favour by the jurisdictional High Court in a connected batch of cases. The Revenue did not point out any distinguishing factual feature or any contrary order of the Supreme Court warranting departure from that decision. The challenge was therefore found to be without substance.

Conclusion: The assessee was not liable to deduct tax at source on external development charges, and the issue was decided in favour of the assessee.

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