• Tax Structuring & Compliance: Phased Liquidation of Government-Issued TDR

I am seeking your formal opinion and tax-structuring guidance regarding the phased liquidation of a government-issued Transfer of Development Rights (TDR) certificate in Telangana (GHMC jurisdiction).
​1. Key Metrics & Structure
​Asset: TDR certificate issued by the government in lieu of cash compensation for a land surrender (original land bought in 2004).
​Volume & Price: 3,775 square yards being sold at a market-driven 30% discount (₹55,020/sq. yd) vs. the land circle rate (₹78,600/sq. yd).
​Execution: The entire volume will be liquidated in smaller tranches to multiple buyers over a 6-to-12-month window.
​Revenue Split: Proceed distribution is strictly 53% to me and 47% to my agent.
​2. Technical Assumptions to Validate
​No Capital Gains Tax: Per CIT vs. Srinivasa Setty, a government-issued TDR has a "Nil" cost of acquisition, causing the statutory computation mechanism to fail. The proceeds should be treated as non-taxable capital receipts that can be deposited directly into our regular savings accounts. 
​Exemption from Section 50C: Because a TDR is an intangible asset (not land or buildings), Section 50C does not apply. Selling below the land circle rate will not trigger artificial tax penalties. 
​3. Specific Questions for Your Review
​Tax-Exempt Status: Does the "machinery failure" argument safely immunize this Telangana-issued TDR from Long-Term Capital Gains (LTCG), or does the IT department attempt to link the cost base back to my 2004 land purchase?
​Section 50C & Partial Sales: Can you definitively confirm that Section 50C cannot be invoked on a Partial Deed of Assignment of TDR? 
​Split Payout Mechanics: To enforce our 53%–47% split across multiple buyers, is it legally cleaner to mandate separate, direct RTGS transfers from each buyer at closing, or should we route 100% into a joint account first? 
​GST Exposure: Does the sale of a government-issued TDR to private developers attract GST, and is it covered under the Reverse Charge Mechanism (RCM)?
​Audit Trail: What specific documentation must I maintain from each partial transaction to build an ironclad defense file in case of future tax scrutiny?
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Rgs
Rafi