Purposive interpretation of residential house exemption: unregistered purchase agreement alone does not defeat relief, but investment must be verified...
The article determines that the applicant institute qualifies as a specified person required to deduct TDS under Section 51 read with Notification No.50/2018 CT because substantial regulatory control (not day to day operational control) by the Central Government exists; Supreme Court precedent overrides administrative circulars. It clarifies that "control" denotes regulatory authority sufficient to trigger notification coverage. On contractual threshold, where supply is continuous and performed in parts, the contract as a whole-aggregating all part invoices-determines the threshold for TDS; separate contracts are assessed individually. Outcome: the institute is liable to deduct TDS.
The article determines that the applicant institute qualifies as a specified person required to deduct TDS under Section 51 read with Notification No.50/2018 CT because substantial regulatory control (not day to day operational control) by the Central Government exists; Supreme Court precedent overrides administrative circulars. It clarifies that "control" denotes regulatory authority sufficient to trigger notification coverage. On contractual threshold, where supply is continuous and performed in parts, the contract as a whole-aggregating all part invoices-determines the threshold for TDS; separate contracts are assessed individually. Outcome: the institute is liable to deduct TDS.
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