Wednesday, July 4, 2018

GST on REALTY (contd.)


 B/F (to UPDATE) >

TOP- up
 
RERA - Ongoing Projects >


https://taxguru.in/service-tax/opening-jugglery-work-contract-service-tax.html


< ca.sanjeevkumar@hotmail.com. Phone : 0124-4271552.)
......
https://taxguru.in/goods-and-service-tax/taxation-builder-developer-rajasthan-part-1.html

< https://www.facebook.com/swaminathanv3/posts/1737087063034239

https://taxguru.in/goods-and.../vat-booking-flats-construction-big-question-mark.html

< within POSTS (selected):

 August 29, 2012
 August 22, 2012


 <<<<

In SK Bansal's case, the following propositions were not specifically or adequately addressed; hence not gone into, and decided by court:

A) The implications of the spl. state law are of every relevance ; so much so, require to be considered and kept in focus for deciding why the property (i.e.Flat or Apartment) is, - 
  •  an immovable property; 
  • indivisible composite property; 
  • the agreement for 'sale' is a composite contract, likewise indivisible and inseparable in all respects; and 
  • ascertainment of separate value of each of the three components of sale, including land, is a must; and, as no  fool- and safe-proof machinery has been prescribed for the purpose, 'works contract'  has to treated as a composite and indivisible  contract. In other words, the  attempted levy is a non-starter , hence must fail.
  • Further, provision of any such machinery, if critically viewed and analyzed, is most likely to prove well-nigh an impossible task.    
B) Levy of  VAT requires to be held as ultra vires the Constitution for one and the same reason(s) as for VAT. For, evaluation called for is of the respective portions for levy of ST and VAT; and if there is no such  mechanism for ST , then it goes without saying that there is no mechanism for VAT as well. In other words, the end result of any attempt at fixing, with reasonably acceptable  accuracy, of the portion to levy ST, is in the nature of things amenable to being flawed on more than one ground; and if so, the remainder left , for levy of VAT, could be equally flawed, as a conundrum, with eventual success. On such reasoning, if pressed for, the Del HC Judgment may be regarded to have implicitly decided  also the issue of VAT in taxpayers' favor. 

And, the same proposition as in B) holds good, also for land, being one of the three components of the sale. 
   
Now, almost after 6 yrs from, - the roller coaster wheels have taken a full round- but to be back only in the proverbial Sq. I - launching Pad !

KEY Note:What is abominably sad and deeply regrettable is that , however, the mostly gullible have remained to be awakened from feigned sleep; as said- even a  man fast asleep,
or in the midst of a mid-summer night dream or a state of coma, could be woken up,  but never one feigning asleep ?! 
In continuation  /apropos of , -
Excerpts (as random selected)

>Input Tax Credit is NOT available *

Revised Model GST Law mentions that input tax credit is not available for-
  • works contracts services when supplied for construction of immovable property, other than plant and machinery, except where it is an input service for further supply of works contract service
  • goods or services received by a taxable person for construction of an immovable property on his own account, other than plant and machinery, even when used in course or furtherance of business.
On analysis, one finds this provision is quite contradictory.
For example, any contractor/builder will not enjoy any input tax credit on the input services if he constructs any building. But he will enjoy input tax credit on input service for further supply of works contract service. These two sentences are confusing and contradictory.
Input tax credit is available to both a builder and a taxable person while constructing plant and machinery. But input tax credit is not available to any taxable person who constructs on his own account even if it is for business use.
In case no abatement/ composition is provided, it may lead to significant increase in tax burden, especially if such works contract is taxed at Standard GST rate (which is 18%) and even if subjected to lower tax rate (12%).>

* Now available - See Update

https://housing.com/news/gst-real-estate-will-impact-home-buyers-industry/


CROSS Refer (Blogs) @

http://vswaminathan-swamilook.blogspot.com/2018/06/rera-nd-gst-contd-supplent.html

http://vswaminathan-swamilook.blogspot.com/2018/06/rera-phase-wise-completion.html

http://vswaminathan-swamilook.blogspot.com/2018/04/gst-india.html

http://vswaminathan-swamilook.blogspot.com/2018/03/sale-of-immovable-property-or-deemed.html

http://vswaminathan-swamilook.blogspot.com/2017/09/rera-gst-el-al-ref-links.html

http://swaminathanv208.blogspot.com/2016/07/deeming-legal-fiction-contd.html


http://swaminathanv208.blogspot.com/2016/07/deeming-legal-fiction-contd.html







To ADD: On a rapid glance through the overwhelmingly too large number of suggestions, mostly of a procedural nature, on aspects in respect whereof, without due acceptance and clarity, implementation and proper compliance may be rendered /prove a noon-starter  ;  but, except for a negligible number of them, the rest do not, so far as known, seem to have been made a conscious note of and acted upon. 
Incidentally, wprt item F, in particular as regards the move to have "the inclusion of .....and stamp duty in GST", which  needs to be completed, the purport or import of the suggestion is not at all clear, much less understood. Be that as it may, going by one's honest guess,  mention of 'stamp duty  in GST' is intended to yet again pin point the need for the duty to be subsumed by the GST; more specifically the duty paid on 'immovable property' . Premised so, as of now, levy of GST on immovable property  is , at best a proposal, and left to be discussed. If so, on the strength of the Feed-input supplied  through several Posts  and available in public domain, the suggestion,in one's perspective, should, instead, have been to shelve, and eventually  drop such a proposal . 

<> Any other eminent view or insightful thoughts, with a different stroke, to share; to the end of making an appropriate suggestion for consideration by the government?  

As per own tentative thoughts / view:

'Unit' (Flat/Apartment),inclusive of UDI, is an immovable property; and indisputably so, - and continue to be-  under other laws / for several other purposes- mainly, for TP Act and Stamp Act. 

It is only for GST, by introducing the newly invented concept of 'deemed works contract', -for which purpose the constitution had to be amended, hence so amended,- the extant status of 'immovable property' , excluding land, happens to receive a different treatment. Even so, it continues to be an immovable property for all other purposes- mainly TP Act and Stamp Act. In case, as suggested, if the idea of subsuming stamp duty in GST were to be gone ahead with, to put it with the least complicity, that may not be possible without first suitably amending the Constitution, and then, also all the other related laws. 

Anyone with a different stroke of better thoughts?!       



https://www.facebook.com/swaminathanv3/posts/1724603330949279


within
https://www.hindustantimes.com/business-news/manish-sisodia-calls-for-abolishing-igst-says-collection-money-lying-idle/story-cysfgcG66w0B5L6wTjuniP.html


>>>>>

https://www.facebook.com/swaminathanv3/posts/1733957226680556

did u KNOW?!

RELATED all >https://www.google.com/search…

Within


COURTESY (out of sheer empathy)

OTHERS:

1. Seller principal debtor; implied in the mandate to gross-up for    
     tax
2. Plant and machinery, on sale, a movable property
    For buyer, when installed for use, is a capital asset, entitled to   
   depreciation allowance.

May be worthwhile to keep in mind, the special definition of, among others,  the terms- 'transfer',  'capital asset', and 'immovable property', in the IT Act; for those are of contextual relevance herein. For the plethora of published articles, discussing in details the significance and implication thereof. For, for purposes of accounting by a realtor , and audit of the books of account and the final accounts, those aspects should necessarily be kept in view and followed unscrupulously, with no qualms whatsoever. 

In Comparison, - 

A) A Unit , with UDI in land and common facilities, on sale, is an immovable property; for promoter -seller, his stock-in-trade, right from day to completion of construction .

No right to convert into and sell unsold Units, as 'capital asset' 
 (hence, not taxable as notional income from HP)


B) For GST,  stamp duty is not proposed to be subsumed.
     
Reasons: 

    For, at the time of conveyance, that is /could be conveyed only as
    an immovable property. Hence stamp duty levy by state is
    incumbent / inevitable.

    No possibility of it being subsumed by GST, even remotely ; as , to
    do so, would require firstly an amendment of the Constitution,
    then of the Stamp Act , also drastic amendments of the TP Act ,
    IT Act , and any other related - /interlinked -laws, even if 
   remotely.

C) The proposition that 'deemed works contract' is a misconceived 
     concept  , that is to be regarded as immovable property is still
      open;
      and, if not to be taken as already  settled, would  require to be 
     seriously challenged /  pursued for having the issue fully and
     finally settled. Precisely stated, it is the seller's obligation to do
     so, as he is the principal debtor for defraying the tax liability.

D)  Seller is the person on whom the levy is made; and as the 
     principal debtor,  he is the one who should pursue contesting    
    the levy to the end of ultimate success. 

    Feed- Input  made available through material shared, to be 
    found in public domain, should be of immense guide and helpful
   assistance for seller to do so; necessarily, of course,  in 
   consultation with and under advice of an eminent top
   counsel.

For a host of the material readily available for such purpose , -far more than adequate, which could  be made use of, - suggest to look through the collation of the Blogs , -
@ https://www.linkedin.com/pulse/units-flatapt-all-swaminathan-venkataraman/
 

On the question of 'effective date' , for purposes of compliance or enforcement of any enactment in general, of any law such as for levy of ST/VAT or GST on 'deemed construction contracts', there appears to be a gross misconception on the part of the realtors.


To be precise: 

A) Levy of GST, not yet enacted but still in a state of absolute flux; even if and when made law could apply only prospectively,on or after the specified date of its coming into force.

And, for this purpose, as per governing legal principles in general , and as concluded by apex and other court rulings in particular, the levy could be applicable to incomplete project(s) in respect of which the contract agreement (i.e. the agreement to sell) has been executed and signed, respectively, by each buyer of Unit, after such specified date.

B) For levy of  ST /VAT,  the same principles as in A) above , must 
    equally good. 


     
    Further, having due regard to the legal implications of the above 
   cited  Del. HC  Judgment, and also of the other related Apex and 
   other Court Judgments,etc.,  in any view of the matter, the said 
   levy(ies)  could not be applied - hence no demand or collection
   made- for any period earlier than the date on which a fresh
   enactment is / comes to be made effective; that is, the date on
   which the contract agreement is  executed and signed  by each
   buyer, in  his  individual case.






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