https://www.taxtmi.com/forum/issue?id=120810 Whether a revenue linked periodic payment by a private operator under a PPP concession is GST taxable as consideration for renting of immovable property depends on its legal character: a variable, performance contingent payment that lacks a direct quid pro quo for land use and where the operator bears all operational risk indicates a concession/franchise principal supply rather than a lease. Key tests are the Direct Nexus Test, Substance over Form, and the Dominant Supply Test; taxpayers should document risk allocation, consider public utility exemptions, seek an Advance Ruling, and avoid unilaterally discharging any reverse charge demand. en-us Wed, 11 Mar 2026 20:30:36 +0530 Wed, 18 Mar 2026 04:25:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/forum/issue?id=120810 Whether a revenue linked periodic payment by a private operator under a PPP concession is GST taxable as consideration for renting of immovable property depends on its legal character: a variable, performance contingent payment that lacks a direct quid pro quo for land use and where the operator bears all operational risk indicates a concession/franchise principal supply rather than a lease. Key tests are the Direct Nexus Test, Substance over Form, and the Dominant Supply Test; taxpayers should document risk allocation, consider public utility exemptions, seek an Advance Ruling, and avoid unilaterally discharging any reverse charge demand. Discussion-Forum GST Wed, 11 Mar 2026 20:30:36 +0530 https://www.taxtmi.com/forum/issue?id=120810