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TDS u/s 194C - Addition u/s 201/201(1A) - TDS not deducted from the payments made to contractors under various schemes - The proviso clearly states that nothing contained in subsection (5A)and (5B) shall be applied to a person whose total income is not chargeable to income tax and who does not obtain PAN under any provision of the Act. - the assessee has segregated the contractual payments more than ₹ 5,00,000/- and less than ₹ 5,00,000/- and submitted a statement - CIT(A), in his findings also has observed that where the receipts are more than ₹ 5,00,000/-, the contractors have submitted their returns disclosing the receipts and paid the taxes on the same and hence, it cannot be taxed in the hands of the assessee. - AT