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Property — Sale

You gave your land to a builder for flats: when is the gain taxed?

You signed a development agreement, the builder is constructing, and you are unsure whether you owe capital-gains tax now or only when the flats are ready.

You own a plot in India and have entered a joint development agreement: you give the land, the builder constructs, and in return you get some built flats and often a cash top-up. The worry is timing and cash. Signing the agreement can look like you transferred the land, which would mean a capital gain now, on a project that will not be finished for years and on flats you have not received. From abroad, being taxed on money you have not seen is the fear. For an individual landowner the law defers exactly that, and lines the tax up with the point at which you actually have the flats.
Last reviewed: 26 July 20268 min readReviewed by Preetesh Maloo, CA

The short answer

For an individual or HUF landowner, the capital gain on a joint development agreement is taxed only in the year the completion certificate for the project is issued, not the year you sign the agreement (Section 45(5A)). The sale value is taken as the stamp-duty value of your share of the finished project on the completion date, plus any cash the builder pays you. The catch is that this deferral is lost if you sell your share of the project before the completion certificate, in which case the gain is taxed earlier. On the cash component the builder deducts TDS under Section 195, because you are a non-resident, not the 10% resident rule. And when you later sell the flats you received, their cost is that same deemed value and the holding period starts at completion.

References on this page

  • Section 45(5A): JDA gain for an individual / HUF taxed in the year the completion certificate is issued
  • Section 45(5A) proviso: deferral lost if you sell your project share before the completion certificate
  • Section 194-IC (10%) applies to a resident landowner; a non-resident's cash is under Section 195
  • Section 49(7): cost of the flats received is the deemed value under Section 45(5A)

The gain waits for the completion certificate

Ordinarily, handing over land is a transfer that triggers capital gains at once. A joint development agreement gets special treatment for an individual or HUF landowner. Under Section 45(5A), the gain on giving your land into the project is charged only in the year the competent authority issues the completion certificate for the whole or part of the project, not in the year you sign the agreement. So you are not taxed years ahead of receiving anything.

When that year comes, the sale value is computed as the stamp-duty value of your share of the finished project, the flats allotted to you, on the completion-certificate date, plus any cash the builder paid you along the way. Two conditions matter: the benefit is for individuals and HUFs, not companies or firms, and the development agreement must be registered. An NRI individual landowner qualifies.

The trap that loses the deferral, and the TDS

The one thing that breaks the deferral is selling early. If you transfer your share in the project, the flats coming to you, on or before the date the completion certificate is issued, Section 45(5A) no longer applies and the gain is taxed in the ordinary way in the year of that transfer. So a landowner who flips their allotment before the project completes gives up the timing benefit; holding to completion preserves it.

On the cash the builder pays you, the deduction of tax matters. The 10% rate under Section 194-IC applies only where the landowner is a resident; because you are a non-resident, the cash consideration is instead subject to TDS under Section 195. There is no TDS on the flats themselves, the in-kind part. As with any NRI sale, a Form 13 lower-deduction certificate can bring the withholding on the cash down to your real tax rather than a flat rate on the gross.

The flats you receive, and selling them later

The flats you get out of the project are a fresh asset in your hands. Under Section 49(7), their cost of acquisition is the same deemed value that was used as your sale consideration under Section 45(5A), the stamp-duty value at completion plus cash, so there is no double counting. Their holding period runs from the completion or allotment date, not from when you first owned the land.

When you later sell one of those flats, it is an ordinary immovable-property sale: long-term if held more than twenty-four months, taxed for an NRI at the flat 12.5% with no indexation for sales on or after 23 July 2024 (Section 112). The resident-only option of 20% with indexation does not apply to you. A practising CA maps the whole arc, the deferred gain at completion, the TDS on the cash, and the cost and rate on any later flat sale.

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What's involved

What the CA actually does

  1. 1

    We time the gain to completion

    We confirm your JDA qualifies for Section 45(5A) and fix the gain to the year the completion certificate is issued, so you are not taxed years ahead on flats you have not received.

  2. 2

    We compute the deemed value

    We work the sale value as the stamp-duty value of your allotted flats at completion plus the cash, and we compute the gain against your land cost, using the 2001 value where the plot is old.

  3. 3

    We handle the TDS on the cash

    We make sure the builder deducts under Section 195 on the cash, not the resident 10% rule, and we file a Form 13 so it is on your real gain.

  4. 4

    We set up the later flat sale

    We record the flats' cost as the deemed value and their holding period from completion, so a later sale is computed correctly at the NRI rate.

What to have ready

Documents you'll typically need

  • The registered joint development agreement
  • The completion certificate, when issued
  • The stamp-duty valuation of your allotted flats
  • Your original purchase records for the land

Your destination country can change the details

Requirements differ from one consulate, university and visa route to the next — how recent the figures must be, how long funds must have been held, and which certificates are mandatory. We assemble the documents around the exact checklist you're applying under. To see how India's tax treaty with your country of residence affects related filings, set your country below or compare all 31 countries.

Frequently asked questions

Common questions

Gave your land to a builder under a JDA?

Send us the agreement and where the project stands. A practising CA will time the gain and the TDS on a free call, no obligation.

No card, no obligation. All certification and filing work is handled by ICAI-registered practising Chartered Accountants.