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The HC upheld the decision favoring the assessee, concluding that External Development Charges (EDC) received by a government authority from private builders constitute "rent" for use of land and therefore fall within the taxable ambit under the relevant TDS provisions; the Assessing Officer's characterization was upheld and the Revenue cannot reclassify such EDC as contractor payments. The Court found the identical issue in prior proceedings between the same parties decided in favour of the assessee, and accordingly affirmed that TDS treatment premised on rent is correct, precluding the Revenue's attempt to treat EDC as payments to a contractor under a different provision.
The HC upheld the decision favoring the assessee, concluding that External Development Charges (EDC) received by a government authority from private builders constitute "rent" for use of land and therefore fall within the taxable ambit under the relevant TDS provisions; the Assessing Officer's characterization was upheld and the Revenue cannot reclassify such EDC as contractor payments. The Court found the identical issue in prior proceedings between the same parties decided in favour of the assessee, and accordingly affirmed that TDS treatment premised on rent is correct, precluding the Revenue's attempt to treat EDC as payments to a contractor under a different provision.
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