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    <title>2012 (6) TMI 234 - GUJARAT HIGH COURT</title>
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    <description>Contracts for carriage of goods and passengers by road transport other than railways were treated as &quot;work&quot; within section 194-C of the Income-tax Act, because the arrangement concerned transportation by trailers, utility vans, water tankers, sumos and similar vehicles. The payment was not &quot;rent&quot; under section 194-I, as that provision applies to use of land, building, machinery, plant, equipment or similar assets, not a carriage contract. The provisions were read as operating in distinct fields, and the interpretation favourable to the assessee was preferred where two views were possible. On that basis, deduction under section 194-C was correct and the demand under section 201(1) was unsustainable.</description>
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    <pubDate>Tue, 06 Mar 2012 00:00:00 +0530</pubDate>
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      <description>Contracts for carriage of goods and passengers by road transport other than railways were treated as &quot;work&quot; within section 194-C of the Income-tax Act, because the arrangement concerned transportation by trailers, utility vans, water tankers, sumos and similar vehicles. The payment was not &quot;rent&quot; under section 194-I, as that provision applies to use of land, building, machinery, plant, equipment or similar assets, not a carriage contract. The provisions were read as operating in distinct fields, and the interpretation favourable to the assessee was preferred where two views were possible. On that basis, deduction under section 194-C was correct and the demand under section 201(1) was unsustainable.</description>
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