Hyderabad builders · HMDA · GHMC · TS-RERA
A Kokapet, Financial District, Kondapur or east-Hyderabad project does not run on approvals alone. The same project must survive the TS-RERA portal, HMDA or GHMC sanction and LRS/BRS history, income-tax timing under the JDA, and GST on construction inputs, cement and TDR/FSI. The margin is usually lost where those four records describe different versions of the project.
Project control
The Hyderabad file should be controlled from land aggregation to completion—not reconstructed when the first TS-RERA update, lender review or tax notice arrives.
01
Reconcile title, survey extent, zoning, access and development potential before the financial model is treated as settled. For HMDA or GHMC parcels, establish whether any unauthorised layout or construction depends on an operative LRS or BRS notification.
TS checkpoint: LRS/BRS is a separate regularisation track. It does not approve, replace or cure RERA registration.
02
Model the landowner share, developer share, consideration, stamp exposure and timing of capital gains before signing. Section 45(5A) can defer an eligible individual or HUF landowner’s capital gain to the completion-certificate year under a registered specified agreement.
TS checkpoint: compute JDA stamp duty under the prevailing Telangana G.O. and verify the applicable rate and registration fee on the execution date.
03
Tie the financial feasibility to the sanctioned use, buildable area, unit schedule and approval conditions. Capture the HMDA or GHMC sanction identifiers and ensure the sanctioned plan, survey coordinates and project records describe the same parcel.
Hyderabad checkpoint: map GHMC/HMDA sanction data, survey boundaries and any LRS/BRS status before preparing the RERA filing set.
04
File TS-RERA Form A before advertising, booking or selling when the project area exceeds 500 sqm or the project contains more than eight apartments. Registration is phase-specific where the development is launched in phases.
TS checkpoint: use the Telangana Authority’s forms and portal at rera.telangana.gov.in—not the AP-RERA portal or AP forms.
05
Deposit 70% of amounts realised from allottees in the separate project account and withdraw in proportion to completion, supported by the certificates required by section 4(2)(l)(D). Keep sales, cost, bank and physical-progress records aligned.
TS checkpoint: complete quarterly project updates on the TS-RERA portal and monitor cement, TDR/FSI and registered-supplier GST positions.
06
Reconcile the completion certificate, final unit inventory, promoter collections, project costs and separate-account utilisation. Complete the annual section 4(2)(l)(D) audit and determine GST under reverse charge on the prescribed unsold-at-CC base.
Hyderabad checkpoint: close HMDA/GHMC approval records, TS-RERA disclosures, TDR/FSI accounting and lender reporting as one evidence file.
CA workstreams
Telangana retained the central registration threshold: registration is required where project area exceeds 500 sqm or the project has more than eight apartments. Under Rule 3 of the Telangana Rules, residential registration fees are ₹5 per sqm up to 1,000 sqm and ₹10 per sqm above 1,000 sqm; the commercial rate is ₹20 per sqm. The important AP–TS distinction is the authority, portal, forms and filing record—not a different section 3 threshold.
Threshold review, promoter and project data collation, sanctioned-plan reconciliation, cost estimates, declarations and Form A filing support under the Telangana Real Estate Rules, 2017.
Hyderabad-specific: TS-RERA Form A and, where relevant, Form D extension filing sets are prepared against the Telangana portal workflow.
Independent CA certification aligned with engineer and architect progress, project-bank records and the proportionate-withdrawal discipline in section 4(2)(l)(D).
Hyderabad-specific: GHMC/HMDA sanction references and project coordinates are mapped to the certified project and phase.
Quarterly reconciliation of bookings, collections, construction progress, approvals and project-bank movements before portal disclosures are filed.
Hyderabad-specific: the disclosure pack follows TS-RERA portal fields rather than an AP-RERA filing rhythm copied from a neighbouring project.
Year-end examination of collections, withdrawals and project utilisation, completed within six months after the financial year as required by the RERA Act.
Hyderabad-specific: the audit trail connects TS-RERA disclosures to the separate account and the HMDA/GHMC-approved phase.
A controlled pack covering project cost, receivables, inventory, approvals, RERA status, tax exposures, separate-account movements and cash-flow sensitivities.
Hyderabad-specific: Kokapet and Financial District models separately identify TDR/FSI premium accounting and unsold-at-CC exposure.
Protect the spread
TS-RERA reporting is state-administered. JDA capital-gains timing, the real-estate GST notifications and section 269ST are pan-India. A Hyderabad project therefore needs Telangana approval records and national tax rules in one model.
01
For residential real estate, the post-1 April 2019 structure generally applies 1% to affordable residential apartments and 5% to other residential apartments without ITC. The former 8%/12% with-ITC route survives only where a qualifying ongoing project validly exercised the prescribed option under Notification 3/2019-CT(R). Cement bought from an unregistered supplier attracts promoter RCM at 28%; the prescribed registered-procurement shortfall attracts RCM at 18%.
02
For an individual or HUF landowner under a registered specified agreement, section 45(5A) can defer capital gains to the year in which the competent authority issues the completion certificate. A transfer of the landowner’s project share before that certificate can take the arrangement outside the deferral. Model deferral against any commercially accelerated exit before documents are signed.
03
Notifications 4/2019 and 5/2019-CT(R) place prescribed TDR/FSI liability on the promoter under reverse charge. The residential exemption is tested against apartments booked before completion; the proportion attributable to residential apartments remaining unsold at the completion certificate becomes the critical closeout exposure.
04
Section 269ST bars receipt of ₹2 lakh or more in cash from a person in a day, for a single transaction, or for transactions relating to one event or occasion. Splitting an advance does not neutralise those tests. Section 271DA can impose a penalty equal to the amount received in contravention.
Why HRA?
The objective is not another parallel spreadsheet. It is a defensible bridge between the sanctioned project, TS-RERA disclosures, project bank account, tax positions and management margin.
Harun Raaj & Associates is a firm of Chartered Accountants based in Visakhapatnam, with extended coverage for Hyderabad builders operating within TS-RERA jurisdiction across HMDA and GHMC areas.
Section 4(2)(l)(D) certification and annual project audit require an evidence-led examination of collections, withdrawals and utilisation. We preserve practical independence from the builder’s routine compliance CA and book-keeping process so the certificate is not a self-review.
Hyderabad builder FAQs
Yes. The Real Estate (Regulation and Development) Act, 2016 applies in both states, so the substantive consequences in sections 59, 61 and 63 come from the same central statute. Telangana’s 2017 Rules and TS-RERA govern local procedure, forms, fees and portal filing. The Telangana Authority publishes its orders on rera.telangana.gov.in; do not use AP-RERA forms merely because the statutory threshold or penalty section is the same.
Yes, if section 3 is triggered: the project area exceeds 500 sqm or the project has more than eight apartments. LRS/BRS schemes regularise specified unauthorised layouts or constructions under a separate state process. They do not grant RERA registration. An LRS-approved project crossing the section 3 threshold must still be registered before advertising, marketing, booking or sale.
Use an independent CA in practice for the section 4(2)(l)(D) certification and keep that role separate from the builder’s routine book-keeping and compliance function. The withdrawal certificate must independently support the percentage-of-completion withdrawal alongside the architect’s and engineer’s certificates; it should not become a self-review of records prepared and controlled by the same compliance team.
No. Section 269ST tests cash receipts against three separate limits: ₹2 lakh or more from one person in a day, for one transaction, or for transactions relating to one event or occasion. Splitting instalments, receipts or days does not cure a breach where the single-transaction or single-event test applies. Section 271DA provides for a penalty equal to the prohibited receipt.
Yes. A project developed in phases may obtain separate registration for each phase under section 3 read with section 5 and the TS-RERA Rules. Each registered phase is treated as a standalone project for its disclosed approvals, completion schedule, separate-account controls and reporting. The phase boundaries must agree with the sanction, inventory, cost records and marketing material.
The promoter must examine reverse charge under Notification 5/2019-CT(R). Notification 4/2019-CT(R) provides the prescribed exemption for TDR/FSI attributable to eligible residential apartments booked before completion, while the proportion attributable to residential apartments remaining unsold at completion certificate is brought to tax under the notification mechanism. Commercial attribution and the underlying supply documents must be reviewed separately.
Do not decide from an AP comparison or a rate copied from an older deed. Telangana duty is governed by the prevailing TS G.O. and must be verified when the JDA is executed. The currently cited Telangana position is 0.5% of the market value of the built-up-area share or the consideration, whichever is higher, plus registration fee—but the operative G.O., valuation and rate should be checked at execution.
No. Under Notification 3/2019-CT(R), a residential real estate project qualifies as an RREP only where commercial-apartment carpet area does not exceed 15% of the total carpet area. At 20%, the project is an REP rather than an RREP. Commercial apartments in an REP fall under the 18% GST entry with ITC, subject to the notification’s valuation mechanism, including the prescribed deemed land deduction where applicable.
