Procurement cost treatment for transport charges meant TDS provisions did not apply on the facts.

Transportation and other charges paid in a purchase and sale transaction were treated as part of the cost of procurement of wheat, not as separate interest, rent or contractual payments. On that factual basis, the TDS provisions were held inapplicable, and the Court relied on its earlier identical decision to support the same view. The revenue's proposed issue was therefore not treated as a substantial question of law, and the appeal was dismissed.

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Issues: Whether the payments towards transportation and other charges formed part of the cost of procurement in a purchase and sale transaction, so that deduction of tax at source under the relevant provisions was not required and no substantial question of law arose.

Analysis: The Tribunal had found that the impugned payments were not made on behalf of the assessee as separate items of interest, rent or contractual payments, but were part of the cost of procurement of wheat. The Court noted that an identical matter had already been decided by it on the same view, thereby supporting the Tribunal's conclusion that the TDS provisions were inapplicable on these facts.

Conclusion: The question proposed by the revenue was not a substantial question of law, and the appeal was dismissed.

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