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    <title>2016 (2) TMI 892 - ITAT DELHI</title>
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    <description>Payments for erection, testing, commissioning and trial operation of plant and machinery were treated as works contract consideration under section 194C, because the contracts involved execution of physical work under specified drawings and supervision and produced a tangible output; the presence of skilled engineers did not by itself make the payments fees for technical services under section 194J. Where the sub-contractors had already offered the receipts to tax, the payer was not to be treated as an assessee in default under section 201 for recovery of the same short deduction.</description>
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