https://www.taxtmi.com/caselaws?id=260083 The dominant issue was whether payments by the assessee to a manufacturer for producing goods constituted "work" under s. 194C, attracting TDS, or a sale transaction. The HC held that where the assessee did not supply any raw material to the manufacturer, and any know-how shared was not transferred for consideration by way of licence fee or royalty, the arrangement could not be characterised as contract manufacturing within the Explanation to s. 194C. Relying on analogous reasoning adopted by another HC in a similar fact situation, the HC determined that s. 194C was inapplicable; accordingly, no TDS obligation arose on such payments and the issue was decided in favour of the assessee against the Revenue. en-us Mon, 30 Mar 2015 00:00:00 +0530 Thu, 08 Jan 2026 15:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=260083 The dominant issue was whether payments by the assessee to a manufacturer for producing goods constituted "work" under s. 194C, attracting TDS, or a sale transaction. The HC held that where the assessee did not supply any raw material to the manufacturer, and any know-how shared was not transferred for consideration by way of licence fee or royalty, the arrangement could not be characterised as contract manufacturing within the Explanation to s. 194C. Relying on analogous reasoning adopted by another HC in a similar fact situation, the HC determined that s. 194C was inapplicable; accordingly, no TDS obligation arose on such payments and the issue was decided in favour of the assessee against the Revenue. Case-Laws Income Tax Mon, 30 Mar 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=260083