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    <title>2025 (8) TMI 59 - BOMBAY HIGH COURT</title>
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    <description>At the interim stage, the Bombay High Court found a strong prima facie case that tax deduction at source was not attracted on issuance of transferable development rights certificates in lieu of compensation. The Court read the words &quot;or by any other mode&quot; in Sections 194C and 194LA ejusdem generis with payment by cash, cheque or draft, and noted that those provisions did not appear to cover kind-based discharge through TDR certificates. It also drew support from Sections 194B and 194R, which expressly deal with payment wholly or partly in kind, indicating that such language was absent from Sections 194C and 194LA. Operation of the impugned order, demand notice and penalty notice was stayed pending final disposal.</description>
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    <pubDate>Mon, 28 Jul 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=775872</link>
      <description>At the interim stage, the Bombay High Court found a strong prima facie case that tax deduction at source was not attracted on issuance of transferable development rights certificates in lieu of compensation. The Court read the words &quot;or by any other mode&quot; in Sections 194C and 194LA ejusdem generis with payment by cash, cheque or draft, and noted that those provisions did not appear to cover kind-based discharge through TDR certificates. It also drew support from Sections 194B and 194R, which expressly deal with payment wholly or partly in kind, indicating that such language was absent from Sections 194C and 194LA. Operation of the impugned order, demand notice and penalty notice was stayed pending final disposal.</description>
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