Minutes of the 34th GST Council Meeting held on 19th March, 2019
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..... Decisions/Recommendations of the IT Grievance Redressal Committee for information of the Council 5. Recommendations of the Joint Committee (Fitment Committee and Law Committee) on Real Estate Sector 6. Creation of the State and Area Benches of the Goods and Services Tax Appellate Tribunal 7. Any other agenda item with the permission of the Chairperson (i): Approval of the draft Removal of Difficulty Order for giving effect to the decisions of 32^nd GST Council Meeting for MSME sector (including small traders) 8. Date of the next meeting of the GST Council Preliminary Discussion: 3. The Hon'ble Chairperson welcomed the Members for the 34^th Meeting of the Council. He stated that before taking tip the Agenda items, there were some important formal items, which he wished to take up. He placed on record the appreciation of the services of late Manohar Parrikar to the GST Council. He was the Chief Minister of Goa and former Defence Minister of India and also held the portfolio of Finance Minister of Goa and attended 13^th and 22^nd Meetings of the Council. He stated that it was unfortunate that he passed away on 17^th March, 2019 and,....
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....e the following portion "rather than by including the cost of land" as the Hon'ble Minister did not refer anything about the cost of land. The proposed change, in strike through mode, would be as follows: 'He suggested that these two models should be considered by the Council for being taxed only on the construction cost.' The Council agreed to the suggestion. 4.2. The Secretary further informed that a communication had been received from the State of Rajasthan to make a change in the version recorded in paragraph 25.24 of the Minutes of the Hon'ble Minister from Rajasthan, by substituting the expression 'He also suggested that criterion for affordable housing should be housing with carpet area of 100 sqm or 120 sqm and houses with a carpet area lower than this should be exempt from tax." with the following: 'He also suggested that it should be left to the State to decide what area may he allowed for affordable and non-affordable housing projects.' The Council agreed to this suggestion. 4.3. The Hon'ble Minister from West Bengal stated that during the last Meeting of the Council on 24^th February, 2019, at the fag end of the discussion on Agenda item relating to real estate s....
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....ailable on the website, www.cbic.gov.in. Act/Rules Type Notification/Circular/Order Nos. CGST Act/CGST Rules Central Tax 9 to 14 of 2019 Central Tax (Rate) 2 of 2019 UTGST Act Union territory tax 2 of 2019 Union territory tax (Rate) 2 of 2019 Circulars Under the CGST Act 92 to 93 of 2019 ROD Orders Under the CGST Act 3 of 2019 Under the UTGST Act 2 of 2019 7.1. The Notifications, Circulars and Orders issued by the States which are pari materia with above Notifications, Circulars and Orders were also deemed to have been ratified. Agenda Item 3: Decisions of the GST implementation Committee (GIC) for information of the GST Council 8. The Secretary invited the Principal Commissioner (GST Policy Wing), CBIC, to brief the Council on this Agenda item. The Principal Commissioner (GST Policy Wing), CBIC, made a presentation which is attached as Annexure 3 to the Minutes. He stated that after the 33^rd Council Meeting, the GIC met once and took certain decisions relating to amendments to CGST Rules, issue of circulars clarifying certain issues and the deferment of e-WalIet scheme and extending exemption from IGST and Ce....
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....at on 15^th March 2019. 12.1. He further stated that that since the Model Code of Conduct due to elections was in force, a reference was made to the Election Commission on 12^th March, 2019 for their permission to implement the decisions of the 33 Council Meeting regarding the GST rates on Real Estate Sector (1% and 5%) and the issue of Removal of Difficulty Order for Composition Scheme for suppliers of service (6% tax rate). Approval from Election Commission was received on 14^th March, 2019 to implement the same. However, the Election Commission had imposed certain conditions that the decisions of today's meeting approving the procedure should be restricted to the substantive decisions already taken and no new decision could be taken. Further, it was also mentioned by them that no briefing to public or press on today's meeting should be done by any political functionary. The Hon'ble Chairperson thereafter stated that the Secretary may do the briefing. 12.2. The Secretary then requested Shri Manish Sinha, Joint Secretary, TRU II to apprise the Council on the main points relating to Draft Rules, Circulars and Notifications placed before the Council. JS TRU II made a presentat....
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.... promoter with conditions as mentioned therein. Document 1A contained illustrations to transitional provisions while Document 2 sought to exempt supply of TDR, FSI (including additional FSI), Long Term Lease of land (against upfront payment in the form of premium, salami, development charges etc.). Similarly, Document 3 was for notifying tax liability on promoter under sub-Section (3) of Section 9 (RCM) on receipt of services from unregistered person, namely Transfer of Development Rights or FSI (including additional FSI) and Long Term Lease of Land (against upfront payment in the form of premium etc.). Document 4 was to notify shifting of the date on which liability to pay tax on TDR, FSI and Long-Term Lease would arise to the date of issuance of Completion Certificate for construction of Real Estate Project (REP) / Residential Real Estate Project (RREP) under Section 148 of CGST Act. Document 5 was for invoking Reverse Charge Mechanism (RCM) under Section (4) of Section 9 of CGST Act, to make the promoter liable to pay tax on shortfall from minimum purchase of specified goods and services from registered suppliers under RCM. Document 6 was to notify a new rate of 18% on supply of....
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....flats that were sold after issuance of Completion Certificate. The date on which builder shall be liable to pay tax under RCM in respect of flats sold after issuance of completion certificate was also being shifted to the date of issue of completion certificate. 12.8. The transitional issues were also explained to the Council in the presentation for computing lIC to be allowed or lapsed. he explained about the proposed amendments to GST Rules vis-à-vis (a) fjnalization of lic at the end of the project as well as financial year wise and (b) apportionment of ITC based on area of commercial and residential apartments in the project. 12.9. He, thereafter, placed the drafts of Notifications, Rules and Orders as explained above for approval of the Council so that once approved, the same could be issued after vetting by the Ministry of Law and Justice, Government of India, to be effective from 01^st April, 2019. He further added that inputs / comments / suggestions received from States in relation to the draft notifications etc. shall be examined in consultation with the Ministry of Law and Justice, Government of India at the time of vetting. He also suggested that proposals ....
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....ime was lost in travelling. In view of the same, the Maharashtra Government had decided to provide affordable houses near the work places in Metropolitan area. However, it was difficult to stick to the guidelines of area upto 60 sqm and value upto Rs. 45 lakh, in view of Mumbai being the costliest city in India and ranking 13^th in the world. Hence, the threshold of Rs. 45 lakh for Affordable Houses may be raised to Rs. 75 lakh in case of Mumba MMR. c. Thirdly, Real Estate Sector in Mumbai was facing crisis. Only 10% to 20% flats were being sold during construction and buiiders were sitting with vacant constructed flats in their hands. If benefit of ITC was disallowed to the sector, it would go into further crisis affecting also the banks along with the builder/developer. Thus, in the transition period, should allow GST rate of 12% and 8%, as applicable, along with the ITC. Although revenue was a concern for the Council, but to move the country ahead, Council should also think that instead of providing subsidy under affordable housing projects, environment should be created where people were enabled to obtain good quality housing under these projects at affordable rates. ....
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....ted that as Council Members, either we swim together or sink and expressed his apprehension that Council was about to initiate a scheme which did not seem to be workable and perhaps which an aberration was in GST with no precedence in the world. Real Estate was a complex, evasion prone sector and the proposal would have a great impact on revenue as was evident from CPWD and NBCC figures where net of ITC, tax was 5% to 7% but actual payment in case of others in cash was not even 1/3^rd of it. He observed that the difference in two was because of large amount of ITC reversal in respect of completed properties which had not been done yet. The 40-page notification before the Council with a bundle of exceptions carved out by invoking extraordinary power under various sections, like Section 9,15,16,148 would result ¡n maintaining a new set of accounts project wise for both i.e. future as well as ongoing projects instead of registration wise maintenance of books of accounts as prevailing now. The credit was claimed and utilized through returns; and returns would have to be reopened in view of the proposed retrospective legislation. The sum and substance of invoking all these powers,....
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....ators of employment and was in real crisis. The main reason for crisis was the perception about high rate of tax of 12% leading to many builders having stopped building while buyers had stopped purchasing. Now, after rate reduction, the builders were of the view that at least their concerns had been heard and the sector might start moving. He was of the view that it was a work in progress and the issues such as commercial construction, exclusion of land value etc. could be considered appropriately, as and when required. However, as of now, Council had to decide the issues within the guidelines of the Election Commission vis-à-vis the 33id Council Meeting decisions. The GoM may continue its work on the fresh proposals and come up with its recommendations which might be considered after the election. 12.17. The Hon'ble Minister from West Bengal raised a question whether the Council could digress under the Model Code of Conduct from the decisions already taken in the 33^rd GST Council Meeting i.e., raising Rs. 45 lakh threshold for Affordable Housing in view of the various proposals placed before the Council by the Hon'ble Ministers from Maharashtra and supported by Gujarat.....
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....cil. He had also discussed the matter with various builders and stakeholders as to whether they would like to join the new proposed scheme of taxation or continue with the old tax rates with ITC. Feedback received reflected that for new projects, 1% and 5% without ITC for Affordable and non-Affordable Houses respectively seemed acceptable and Bihar agreed with Maharashtra, Gujarat, West Bengal and other States in this regard. However, for ongoing projects, reversal would be an issue creating a liquidity problem due to huge reversals that might be required as part of the proposed scheme. Thus, Council might define the term 'ongoing' with reference to a project (whether 80% complete or just started etc.) and provide the option to address the issue. Further, he drew attention on page no.135 of the agenda note wherein as per the explanation to Section 80, the Commissioner had been given power to fix the monthly installment for payment of the ITC reversal amount. In his opinion, the Commissioner should not be given any discretionary power and it should be inbuilt in the mechanism. He also suggested that since the annual returns would be filed in September 2019, any difficulties arising ....
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....l meeting could be held immediately after elections to decide the pending issues. Thus, in the meeting, the Council might decide on the specific issue of option on pro-rata ITC reversal for ongoing projects as raised by the Hon'ble Minister from West Bengal. Thereafter he invited the members to provide their views on the issue of option for ongoing projects, so that it could be settled. 12.21. The Hon'ble Deputy Chief Minister of Delhi sought clarification as to whether the issue of option for the ongoing projects was being referred to GoM or not, to which, the Hon'ble Chairperson clarified that it was not being referred to the GoM and the Council had to take a decision on this issue. He further clarified that it was covered within the clearance of the Election Commission for the meeting since it was related to the decision on transition. The Hon'ble Minister from Punjab stated that he preferred that there should not be any option for all the ongoing projects as on 31.03.2019 to avoid complication, and from 1.04.2019, all projects should be covered in the new scheme. L-le stated that he was agreeing with the proposition of West Bengal only with a variation that there should not ....
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....nition should mean a building construction which had commenced prior to 31^st March, 2019. However, he added that the officers would clearly draft the definition so that there was no misuse. The Hon'ble Minister from West Bengal stated that the existing draft notification already contained the definition of REP (Real Estate Project) which was already before the Council. However, he suggested that the final definition should be circulated to all the States so that before it was notified, all the States could give their views on the same. The Secretary stated that the definition of the 'Ongoing Project' in the notification would be to include the building which had commenced prior to 31^st March, 2019 and would have the option whether to go for a suggested formula as drafted or continue with the old formula. The Hon'ble Chairperson concluded that the GST Council Secretariat might consult with all the States before finalizing the definitions so that, there was no misuse of the transition. Thus, before finalization of the definition, the Secretariat would invite views of Punjab. West Bengal and also Haryana. He further observed that, consensus seemed to be in the favor of the propositi....
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....s to be given a one-time option to continue to pay tax at the old rates (effective rate of 8% or 12% with ITC) on ongoing projects (buildings where construction and actual booking had both started before 01.04.2019) which could not be completed by 31.03.2019. The option to be exercised once within a prescribed time frame and where ever the option not exercised within the prescribed time limit, new rates to apply. 13.2. Applicability of new tax rates: The new tax rates to be applicable to new projects or ongoing projects which have exercised the option to pay tax in the new regime subject to decision at paragraph 13.1 above, as follows: (i) New rate of 1% without input tax credit (ITC) on construction of affordable houses to be available for, a. all houses which meet the definition of affordable houses as decided by the Council (area 60 sqm in metros /90 sqm in non- metros and value upto Rs. 45 lakh), and b. affordable houses being constructed in ongoing projects tinder the existing Central and State housing schemes presently eligible for concessional rate of 8% GST (after 1/3^rd and abatement). (ii) New rate of 5% without input tax credit to b....
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....cing after 01.04.2019: a. Supply of TDR, FSI, long term lease (premium) of land by a landowner to a developer to be exempted subject to the condition that the constructed flats are sold before issuance of completion certificate and tax was paid on them. b. Exemption of TDR, FSI, long term lease (premium) to be withdrawn in case of flats sold after issue of completion certificate but such withdrawal to be limited to 1% of value in case of Affordable Houses and 5% of value in case of other than Affordable Houses. c. The liability to pay tax on TDR, FSI, long term lease (premium) to be shifted from land owner to builder under the Reverse Charge Mechanism (RCM). d. The date on which builder to be liable to pay tax on TDR, FSI, Long Term Lease (premium) of land under RCM in respect of flats sold after completion certificate to be shifted to date of issue of Completion Certificate. e. The liability of builder to pay tax on construction of houses given to land owner in a JDA to be also shifted to the date of completion. 13.6. Amendment to ITC rules: ITC rules to be amended to bring greater clarity on monthly and final determination of ITC an....
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....9 States and Puducherry. Subsequently report from one more State, viz. Andhra Pradesh (suggesting Principal Bench at Vijayawada and Area Benches at Vishakhapatnam and Tirupati) and the UT of Delhi (suggesting Principal Bench at New Delhi with no area bench) had been received. Report was awaited from the remaining 10 States. 14.2. He added that since report was pending from 10 States, these States should expedite sending the information about the number of State Benches of GSTAT required as well as the places where they were required to be set up. In the next hearing before the Hon'ble Court, a suitable reply regarding setting np of GSTAT could be filed. Shri Ashok K.K. Meena, Principal Secretary, Finance Department, Government of Odisha stated that for Odisha, they would like to propose State Bench either at Bhubaneshwar or at Cuttack, and that this information would be sent in writing too. 15. For Agenda item 6, the Council took note of the developments regarding the formation of the GSTAT i.e. the numbers of Benches and the places where to locate them. Agenda Item 7: Any other agenda item with the permission of the Chairperson Agenda Item 7(1): Approval of the draft R....
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....n stated that before the General Elections, this was possibly the last meeting of the Council unless it was required to meet for some emergent clarification. He observed that till now, 34 Meetings of the Council had been held and a very large number of man hours had been spent in these meetings. It was heartening to see that Members came to the Meetings with open mind and their political colours outside the Council did not impact economic decisions taken in the Council. He added that the decisions were always arrived at by consensus and where it was felt that it was difficult to reach a consensus, either decision was not taken or the issue was referred to a Group of Ministers before being taken up again for consideration by the Council on the basis of the revised formulation. He observed that the same practice was observed even today where the Council agreed to an alternative formulation from the Hon'ble Minister from West Bengal regarding transition provision for taxation in the real estate sector. He stated that in view of the delicate balance of federalism where Centre and States cooperate and take various decisions by consensus, on behalf of the Council, he expressed the hope t....
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.... Deputy Chief Minister Deputy Chief Minister Deputy Chief Minister Minister for Panchayat Minister, Excise & Taxation Advisor to Governor (I/c Finance) Minister - Department of Urban Development, Housing and Transport Finance Minister Deputy Chief Minister Chief Minister Finance Minister Minister for Local Self Government, Urban Development and Housing, Law and Legal affairs, Parliamentary affairs Minister for Fisheries and Personnel & Administrative Reforms 15 Tamil Nadu Shri D. Jayakumar 16 17 Uttar Pradesh West Bengal Shri Rajesh Agarwal Dr. Amit Mitra Finance Minister Finance Minister Page 18 of 34 MINUTE BOOK Estd. 1949 Annexure 2 List of Officials who attended the 34th GST Council Meeting on 19th March 2019 Dr. A. B. Pandey Dr. Krishnamurthy Subramanian Shri Pranab Kumar Das Dr. John Joseph Shri Sandeep M. Bhatnagar Dr. Rajeev Ranjan Shri Manoj Sethi Shri Upender Gupta Shri G. D. Lohani JAYNA 1 Govt. of India 2 Govt. of India 3 Govt. of India 4 Govt. of India Ms Ameeta Suri 5 Govt. of India 6 Govt. of India 7 Govt. of India 8 Govt. of India 9 Govt. of India 10 Govt. of India 11 15 Govt. of India 12 Govt. of ....
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....6 Govt. of India 57 Andhra Pradesh 58 Andhra Pradesh 59 Andhra Pradesh Shri S. Kannan Shri Javed Akhtar Khan Shri Sanjay Mahendru Shri Viney Kumar Paul Shri A R S Kumar Shri M Srihari Rao Shri Nitin Anand Dr D. Sambasiva Rao Shri J. Syamala Rao Shri T. Ramesh Babu Shri D. Venkateswara Rao Shri Anirudh S Singh Superintendent Superintendent Inspector CEO EVP (Services) Pr. Commissioner, Chandigarh Zone, CBIC Commissioner, Meerut Zone, CBIC Commissioner, Lucknow Zone, CBIC Commissioner, Bhopal Zone, CBIC Pr. Commissioner, Chennai Zone, CBIC Commissioner, Ahmedabad Zone, CBIC Commissioner, Mumbai Zone, CBIC Commissioner, Guwahati Zone, CBIC Commissioner, Hyderabad Zone, CBIC Commissioner, Vishakhapatnam Zone, CBIC Commissioner, Ranchi Zone, CBIC Special Chief Secretary, Revenue Chief Commissioner, State Tax Commissioner, State Tax OSD to Spel Chief Secretary, Revenue Commissioner (Tax & Excise) Assistant Commissioner, State Tax 60 Andhra Pradesh Arunachal 61 Pradesh Arunachal 62 Shri Tapas Dutta Pradesh Arunachal 63 Shri Nakut Padung Superintendent, State Tax Pradesh Arunachal 64 Superintendent, State Tax Pradesh Shri Teli N....
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....issioner, State Tax Addl Chief Secretary, E & T Dept Commissioner, State Tax Addl Commissioner, State Tax Principal Secretary (Excise & Taxation) Commissioner, State Tax & Excise Addl. Commissioner, State Tax & Excise Joint Commissioner, State Tax & Excise Dy. Commissioner, State Tax & Excise Commissioner, State Tax Secretary cum Commissioner, State Tax Addl. Commissioner, State Tax State Tax officer Commissioner, State Tax Commissioner, State Tax Pr. Secretary, State Tax Commissioner, State Tax Jt. Commissioner, State Tax Commissioner, State Tax Joint Commissioner, State Tax Commissioner, State Tax Asst. Commissioner, State Tax Jt. Commissioner, State Tax Asst. Commissioner, State Tax Asst. Commissioner, State Tax Asst. Commissioner, State Tax Superintendent, State Tax SECRETARY'S INITIALS MINUTE BOOK 112 Mizoram 113 Mizoram 114 Mizoram 115 Mizoram 116 Nagaland 117 Nagaland 118 Nagaland 119 Odisha 120 Odisha Puducherry 121 122 Punjab 123 Punjab 124 Punjab 125 Punjab 126 Rajasthan 127 Rajasthan 128 Rajasthan 129 Rajasthan 130 Rajasthan 131 Sikkim 132 Tamil Nadu 133 Tamil Nadu 134 Tamil Nadu 135 Tamil Nadu 136 Telangana 1....
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....Council Deemed ratification & GIC / IT-GRC Decisions Agenda NATION TAX MARKET Agenda No. 2 - Deemed Ratification of Notification / Circulars issued post 33rd Meeting of GST Council • Agenda No. 3 - Decisions taken by the GIC post 33rd Meeting of - Decisions recommendations of the IT GST Council for information of the GST Council Agenda No. 4 Grievance Redressal Committee post 33rd Meeting of GST Council for information of the GST Council Page 23 of 34 2 Marry SECRETARY'S INITIALS SECRETARY'S INITIALS MINUTE BOOK Agenda No. 2 Deemed Ratification (1/1) NATION TAX MARKET • Ratification of following notifications, circulars & orders issued post 33rd meeting (dated 20th February, 2019) of GST Council: Notification / Circular / Act/Rules CGST Act/CGST Rules UTGST Act Type Central tax Central tax (Rate) Union territory tax Union territory tax (Rate) Order Nos. 9 to 14 of 2019 2 of 2019 2 of 2019 2 of 2019 92 to 93 of 2019 ROD Orders Under the CGST Act Under the UTGST Act 3 of 2019 2 of 2019 Circulars Under the CGST Act Agenda No. 3 GIC decisions post 33rd GST Council Meeting (1/4) Decision in 25th GIC meeting (05.03.2019)....
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....ular No. 39/13/2013 dated 03.04.18 prescribing the procedure for taxpayers for lodging their grievance due to technical glitch in the GST system was issued • GIC to act as IT Grievance Redressal Committee (IT- GRC) for resolving problems of the taxpayers who have not been able to file their documents such as TRAN-1, GSTR-3B GSTR-1 or Registration/ migration etc. due to technical glitches at Common Portal • Taxpayers are required to submit their grievance application of technical glitch to the designated field nodal officer of State/Center along with evidence Page 26 of 34 JAYNA BOOK DEPOT MINUTE BOOK Estd. 1949 JB JAYNA Agenda No. 4 Decisions/recommendations of the IT-GRC (2/3) • . INATION TAX MARKET Field nodal officers to examine the taxpayers application and the supporting evidence and if it is prima facie found to be a case of technical glitch then send the issues after collating with their remarks/recommendation to the GSTN Nodal officer by email GSTN issued a SOP on 12.04.18 which is to be followed by the Nodal officers of the States / Center while referring the technical glitches to GSTN IT Grievance Redressal Committee (IT-GR....
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....able. ⚫ The new rate shall become applicable from 1st of April, 2019. ⚫ Details of the scheme shall be worked out by an officers committee and shall be approved by the GST Council in a meeting to be called specifically for this purpose. The meeting took place on 6th March, 2019. Existing tax payout in the Real Estate Sector Calculation of GST payable as per present rate structure Page 3 High Rise Building Low Rise Building Sl. No. Category of Housing Unit Low end Premium finish Quality Affordable Low end finish Affordable 1 Cost of property 4000 10000 3000 3000 2500 (per sq ft.) Cost of 2 ल 1700 3000 1500 1400 1100 construction 3 Input tax credit 280.5 495 247 231 181 4 GST payable (cash 480 1200 240 360 200 + credit) 5 Net GST payable 199.5 705 0 129 19 6 Percentage GST 4.99% 7.05% 0.00% 4.30% 0.76% Payable Page 29 of 34 Source: NBCC Page 4 работата SECRETARY'S INITIALS MINUTE BOOK Joint meeting of Fitment and Law committee . • Joint meeting of fitment committee and law committee took place on 6th March, 2019. 9 states in Law committee, and 11 states in Fi....
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....) of section 9 of CGST Act, to tax TDR, FSI. long term lease and Cement when received by promoter from an unregistered supplier To create a new rate of 18% on supply of any goods other than capital goods and cement falling under chapter heading 2523 in the first schedule to the Customs Tariff Act. 1975 (51 of 1975), by an unregistered person to a promoter by amending notification No. 1/2017- CTR Amendment to rule 42 and 43 of CGST rules for real estate sector. Page 6 Page 30 of 34 JAYNA BOOK DEPOT Estd. 1949 JB JAYNA REP RREP MINUTE BOOK Rate structure as per the new draft notification Description of service Condition SL No. Rate of GST 3 (ia) Construction of affordable residential apartments by a promoter in a residential real estate project (RREP) 1% 3 (ib) Construction of residential apartments other than 5% affordable residential apartments by a promoter in a residential real estate project (RREP) 3 (ic) Construction of commercial apartments (shops, offices, godowas etc.) by a promoter in a residential real estate project (RREP) 5% 3 (id) Construction of affordable residential apartments by a promoter in a real estate project (REP) other t....
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.... a landowner to a developer shall be exempted Conditions Constructed apartments are to be sold before issuance of completion certificate and tax is paid on them (either 1% or 5%). Exemption of TDR, FSI, long term lease (premium) shall be withdrawn in case of flats sold after issue of completion certificate. . Such withdrawal shall be limited to 1% of value in case of affordable houses and 5% of value in case of other than affordable houses. This will achieve tax parity between under construction and ready to move property. Page 9 Draft details on TDR/ JDA, FSI, Long term lease etc. Liability to pay tax • • The liability to pay tax on TDR, FSI, long term lease (premium) shall be shifted from land owner to builder under RCM. The builder shall be liable to pay tax on TDR, FSI and long term lease (premium) to the extent these rights are used in construction of flats that are sold after issuance of completion certificate. The date on which builder shall be liable to pay tax under RCM in respect of flats sold after completion certificate is being shifted to date of issue of completion certificate. Similar change is also proposed in JDA. This is likely ....
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