https://www.taxtmi.com/caselaws?id=184296 The court allowed the writ petition, declaring the impugned circular as ultra vires Section 194C concerning the carriage of goods for hire. The court emphasized that Section 194C does not cover contracts solely for the transportation of goods without additional services. The ruling clarified the distinction between Sections 44AE and 194C, stating they serve different purposes without conflict. The judgment favored the petitioners' interpretation, applying the doctrine of contemporanea expositio and previous CBDT circulars. en-us Tue, 20 Dec 1994 00:00:00 +0530 Tue, 05 Jul 2016 10:41:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=184296 The court allowed the writ petition, declaring the impugned circular as ultra vires Section 194C concerning the carriage of goods for hire. The court emphasized that Section 194C does not cover contracts solely for the transportation of goods without additional services. The ruling clarified the distinction between Sections 44AE and 194C, stating they serve different purposes without conflict. The judgment favored the petitioners' interpretation, applying the doctrine of contemporanea expositio and previous CBDT circulars. Case-Laws Income Tax Tue, 20 Dec 1994 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=184296