https://www.taxtmi.com/caselaws?id=326200 A one-time non-refundable upfront payment for long-term leasehold rights was held not to constitute rent for TDS purposes under Section 194-I. The court treated the substance of the transaction as a co-developer, deemed-sale arrangement for developing a special economic zone, noting that the parties themselves did not treat the amount as ordinary lease rent. As no obligation to deduct tax at source arose, the payer could not be regarded as an assessee in default, and the consequential interest under Section 201(1-A) was unsustainable. The TDS demand and related interest liability were set aside in favour of the assessee. en-us Mon, 04 Apr 2016 00:00:00 +0530 Fri, 08 Apr 2016 12:20:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=326200 A one-time non-refundable upfront payment for long-term leasehold rights was held not to constitute rent for TDS purposes under Section 194-I. The court treated the substance of the transaction as a co-developer, deemed-sale arrangement for developing a special economic zone, noting that the parties themselves did not treat the amount as ordinary lease rent. As no obligation to deduct tax at source arose, the payer could not be regarded as an assessee in default, and the consequential interest under Section 201(1-A) was unsustainable. The TDS demand and related interest liability were set aside in favour of the assessee. Case-Laws Income Tax Mon, 04 Apr 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=326200