Case of CIT (TDS) vs SS Group Pvt Ltd, HC Delhi judgement Dated 18thAugust 2025. HC dismissed the Revenue appeal, affirming that External Development Charges (EDC) paid by a real estate developer to the Haryana Urban Development Authority (HUDA) are not “rent” and do not attract the obligation to deduct Tax Deducted at Source (TDS) under Section 194−I of the Income Tax Act.