Section 194C of the Income-tax Act, 1961 - Deduction of tax at source - Payments to contractors and sub-contractors - Applicability of TDS provisions of section 194C on Contract for Fabrication of Article or Thing as per Specifications given by the Assessee - Contradiction between two Circulars of C

TDS under Section 194C applies only to contracts for work, not to contracts that are effectively sales of fabricated goods.

Payments for manufacture or fabrication to an outside party under specifications will attract tax deduction under section 194C only if the arrangement is, on its true construction, a contract for work; where property in the fabricated article passes to the assessee only on delivery and the arrangement amounts to a contract of sale, section 194C does not apply.