https://www.taxtmi.com/caselaws?id=245701 A composite memorandum of understanding for support services, deputation of personnel, infrastructure and allied facilities was treated as a contract for work and services, bringing the payments within section 194C. The claim that the sums were mere reimbursement without profit element was rejected, so disallowance under section 40(a)(ia) remained sustainable for failure to deduct tax at source. The provision was also read as applying to amounts payable during the previous year, not only to liabilities outstanding at year-end. The contrary Special Bench view was not followed, while the Allahabad High Court order was distinguished as not deciding the point on merits. en-us Wed, 23 Oct 2013 00:00:00 +0530 Sat, 05 Apr 2014 14:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=245701 A composite memorandum of understanding for support services, deputation of personnel, infrastructure and allied facilities was treated as a contract for work and services, bringing the payments within section 194C. The claim that the sums were mere reimbursement without profit element was rejected, so disallowance under section 40(a)(ia) remained sustainable for failure to deduct tax at source. The provision was also read as applying to amounts payable during the previous year, not only to liabilities outstanding at year-end. The contrary Special Bench view was not followed, while the Allahabad High Court order was distinguished as not deciding the point on merits. Case-Laws Income Tax Wed, 23 Oct 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=245701