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Hiring of vehicles to be used for loading & unloading and transportation of products – Merely because the words 'loading & unloading' are used in the contract, no one can presume that the contractee has to do any work on behalf of the assessee. The assessee has to make use of the equipment/vehicle made available on payment of hire for his use. Therefore, it is hire of equipment/vehicle simplicitor and Section 194I would be applicable - AT