In the above case, new member pays transfer fee to the CHS. Whether the buyer of flat will have to pay ST on transfer fee paid to CHS?
Yes. Looking to the wordings of the Explanation, and if CHS is termed as builder, any amount received by the CHS prior to getting the completion certificate is subject to ST. Read the Explanation carefully, the context of receipt of money is missing. It has not been spelt out explicitly. Therefore, on a plain reading, it appears that any amount received by CHS before receipt of completion certificate will be subject to tax.