Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
ITAT adjudicated a tax deduction at source (TDS) dispute under Section 194C, addressing contract manufacturing payment characterization. The tribunal followed its prior coordinate bench ruling for the same assessment year, determining that payments under service agreements did not fall within Section 194C's scope. Consequently, the assessee was not obligated to deduct tax at source. The revenue's challenge was comprehensively dismissed, with the CIT(A)'s original decision upholding the absence of TDS liability and associated interest under Sections 201(1) and 201(1A) being affirmed.
ITAT adjudicated a tax deduction at source (TDS) dispute under Section 194C, addressing contract manufacturing payment characterization. The tribunal followed its prior coordinate bench ruling for the same assessment year, determining that payments under service agreements did not fall within Section 194C's scope. Consequently, the assessee was not obligated to deduct tax at source. The revenue's challenge was comprehensively dismissed, with the CIT(A)'s original decision upholding the absence of TDS liability and associated interest under Sections 201(1) and 201(1A) being affirmed.
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