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Issues: Whether the CBDT circular could validly bring Advocates, Architects and Chartered Accountants within the scope of section 194C of the Income-tax Act, 1961.
Analysis: The Court followed its earlier decision that the expression "carry out any work" in section 194C does not extend to professional services of this nature. The circular could not enlarge the statutory scope by treating such professionals as persons covered by the provision.
Conclusion: The circular, to the extent it applied to Advocates, Architects and Chartered Accountants, was held to be ultra vires section 194C and was struck down.