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Tax deduction at source under section 194C applies to External...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudication.
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Tax deduction at source under section 194C applies to External Development Charges paid to the urban development authority, rendering the payer liable for non-deduction, subject to the pending Supreme Court proceedings. Payments later characterised as administrative charges for changes in beneficial interest and development rights require verification of the supporting evidence, the applicable State scheme, the payments' nature, and any resulting obligations under Chapter XVII-B. Those disputed payments require de novo determination by the Assessing Officer after admission of evidence and an adequate hearing. The Revenue's position succeeded on External Development Charges, while the remaining TDS issue was restored for fresh adjudication.
Tax deduction at source under section 194C applies to External Development Charges paid to the urban development authority, rendering the payer liable for non-deduction, subject to the pending Supreme Court proceedings. Payments later characterised as administrative charges for changes in beneficial interest and development rights require verification of the supporting evidence, the applicable State scheme, the payments' nature, and any resulting obligations under Chapter XVII-B. Those disputed payments require de novo determination by the Assessing Officer after admission of evidence and an adequate hearing. The Revenue's position succeeded on External Development Charges, while the remaining TDS issue was restored for fresh adjudication.
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