2008 (10) TMI 654 - HC - Income Tax

Assessment Year 2003-04: Delhi High Court Rules Transactions Not Works Contracts

Commissioner of Income-tax Versus Seagram Manufacturing (P) Ltd.

The High Court of Delhi, in a case concerning the assessment year 2003-04, ruled that the transactions between the assessee and its suppliers were not ... - Issues involved: Determination of nature of transactions u/s 194C of the I.T. Act, 1961.The High Court of Delhi, in the case concerning the asst. yr. 2003-04, addressed the issue of whether the transactions between the assessee and its suppliers constituted a works contract or sale of goods simplicitor u/s 194C of the I.T. Act, 1961. The court highlighted that if the transactions were deemed to be works contracts, tax deduction at source would have been necessary under s. 194C, leading to potential consequences for the assessee-in-default as per s. 201(1) and liability for interest u/s 201A. Both the CIT(A) and the Tribunal found that the dealings were on a principal-to-principal basis and not in the nature of works contracts, thereby relieving the assessee from the obligations under s. 194C.The Tribunal specifically observed that the case primarily involved a contract for the sale of packing material, distinguishing it from the precedent set by the Supreme Court in the case of State of Tamil Nadu v. Anandam Viswanathan. Consequently, the Tribunal concluded that s. 194C would not be applicable due to the transactions not falling within the ambit of works contracts. The court also cited similar decisions in cases such as CIT v. Dabur India Ltd and CIT v. Reebok India Co., supporting the stance that the provisions of s. 194C were not triggered in the present scenario.Ultimately, the High Court determined that no substantial question of law merited consideration in this case and subsequently dismissed the appeal, affirming the findings of the lower authorities regarding the nature of transactions between the assessee and its suppliers.