Assessee was implementing a slum rehabilitation scheme on a particular plot of land. As per instructions of Slum Rehabilitation Authority, assessee issued Transferable Development Rights (TDRs) to (i) developers, for carrying out development work, and (ii) landowners, as compensation for land acquired for public purposes from original owners. Revenue treated assessee as assessee-in-default for failure to deduct TDS under sections 194C and 194LA on such issuance of TDRs, and also issued consequential demand and penalty notices. On writ the  assessee contended that issuance of TDRs did not amount to payment in ‘cash or by cheque/draft or any other monetary mode’ and, therefore, sections 194C/194LA would not apply, especially since those provisions do not specifically deal with payments in kind unlike sections 194B and 194R. Court held that   prima facie, section 194C and section 194LA would not apply when TDR Certificates are issued in lieu of compensation. Court held that sections 194B and 194R specifically contemplate situations involving payments wholly or partly in kind therefore, assessee having made out a prima facie case, implementation and operation of impugned order passed under sections 201 and 201(1A) deserved to be stayed, and consequently, demand and penalty notices were also to be stayed. Revenue was directed to file reply on or before 25 th August  2025.     (AY. 2021-22)