https://www.taxtmi.com/caselaws?id=779789 ITAT MUMBAI - The tribunal held that payments under the JDA fall within section 194IC and the narrower interpretation urged by the assessee is rejected; leasehold transfers under JDA are taxable and the beneficial reading of subsection (5A) does not exclude such transferors. Consequently the requirement to deduct TDS (and associated liability under section 201(1)/(1A)) stands. The assessee's claim that the transferee had offered the receipts as capital gains was unsubstantiated; the matter is remitted to the AO to verify whether the transferee declared the impugned payments in AY 2024-25. en-us Fri, 10 Oct 2025 00:00:00 +0530 Mon, 13 Oct 2025 08:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779789 ITAT MUMBAI - The tribunal held that payments under the JDA fall within section 194IC and the narrower interpretation urged by the assessee is rejected; leasehold transfers under JDA are taxable and the beneficial reading of subsection (5A) does not exclude such transferors. Consequently the requirement to deduct TDS (and associated liability under section 201(1)/(1A)) stands. The assessee's claim that the transferee had offered the receipts as capital gains was unsubstantiated; the matter is remitted to the AO to verify whether the transferee declared the impugned payments in AY 2024-25. Case-Laws Income Tax Fri, 10 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779789