Clarification regarding applicability of provisions of Section 194-I to payments made by the customers on account of cooling charges to the cold storage owners

Withholding on cooling charges treated as contract payments; apply contractor withholding rules rather than rent withholding.

Cooling charges paid by customers to cold storage owners are not rent because preservation by mechanical process is the primary function and customers acquire no right to use space or machinery; therefore Section 194-I does not apply, and such cooling charges should be treated as contractual service payments subject to withholding under Section 194-C.