Alternative Accommodation Charges to SRA Tenants Not Subject to TDS Under Section 194-IC as Property Share Compensation

ITAT ruled that alternative accommodation charges paid to tenants under SRA scheme do not constitute consideration for share in land/building under development agreement. Following precedent in Nathani Parekh Construction case, tribunal held such payments categorized as 'Rent to Tenant SRA' fall outside scope of TDS provisions under section 194-IC. CIT(A)'s order deleting tax and interest levied under sections 201(1) and 201(1A) upheld. The ruling clarifies that temporary accommodation expenses during redevelopment are distinct from property share compensation, exempting them from TDS requirements. Appeal resolved in taxpayer's favor. .....

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