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of TDS u/s 194C - payment of freight charges w/o deducting TDS - tripartite agreement - payment made to the Truck Operator Union (through the assessee company) - The ITAT found that the primary liability to deduct TDS rested with M/s Pepsico India Holding Pvt. Ltd., as they were the principal party responsible for the transportation of their goods. The Tribunal observed that the assessee merely facilitated the payment process by routing the payments from M/s Pepsico India Holding Pvt. Ltd. to the truck operator union. - The Tribunal agreed with the assessee's contention that it acted as an intermediary. The ITAT noted that the assessee did not own any trucks and its primary business was providing logistical support, coordination, and raising invoices on behalf of the truck operator union. - The ITAT concluded that the provisions of Section 194C were not applicable to the assessee regarding the non-deduction of TDS on freight payments.
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