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    <title>2016 (3) TMI 1019 - ITAT NAGPUR</title>
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    <description>The Tribunal dismissed the Revenue&#039;s appeal, upholding the deletion of the addition under Section 40(a)(ia) as the amount was paid and not payable at the end of the year. Additionally, it was found that the appellant did not have contractual obligations with truck owners that would constitute a subcontract under Section 194C(2), leading to the inapplicability of TDS deduction. The decision was supported by judicial precedents and the absence of evidence of formal contracts with truck owners.</description>
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      <description>The Tribunal dismissed the Revenue&#039;s appeal, upholding the deletion of the addition under Section 40(a)(ia) as the amount was paid and not payable at the end of the year. Additionally, it was found that the appellant did not have contractual obligations with truck owners that would constitute a subcontract under Section 194C(2), leading to the inapplicability of TDS deduction. The decision was supported by judicial precedents and the absence of evidence of formal contracts with truck owners.</description>
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