
Section 104 Finance Act | Upfront 50% Water Infrastructure Cost in 99-Year Industrial Leases Exempt as One-Time Payment, Not Support Service : CESTAT Chennai
CESTAT Chennai rules that the 50% upfront capital contribution by industrial lessees toward water supply infrastructure is a one-time, non-recurring payment exempt under Section 104 of the Finance Act, 1994, and cannot be taxed as a support service. This clarifies the tax treatment of long-term industrial lease arrangements involving shared infrastructure costs, benefiting state industrial promotion bodies and manufacturing tenants nationwide.
