Non adjudication of grounds by tribunal - Liability of TDS u/s...

Non adjudication of grounds by tribunal - Liability of TDS u/s 194C - Tribunal ought to have rendered a finding on the grounds raised by the assessee with regard to the applicability of Section 194C on the IUC paid to the other telecom operators and remanded on alternative ground - without any finding on the applicability of Section 194C the order passed by the Tribunal should be and shall be read as an open remand to the AO