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    <title>2018 (1) TMI 972 - ITAT AGRA</title>
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    <description>Payments received from contractee departments and passed on to a sub-contractor were treated as routed funds rather than retained income, so the factual basis for treating the amount as taxable income was not established. On those facts, the alleged failure to deduct tax at source under Section 194C did not justify disallowance, and the attempted invocation of Section 40(a)(ia) also could not sustain the addition. The stated result was deletion of the disallowance in favour of the assessee, with the appeal succeeding.</description>
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      <description>Payments received from contractee departments and passed on to a sub-contractor were treated as routed funds rather than retained income, so the factual basis for treating the amount as taxable income was not established. On those facts, the alleged failure to deduct tax at source under Section 194C did not justify disallowance, and the attempted invocation of Section 40(a)(ia) also could not sustain the addition. The stated result was deletion of the disallowance in favour of the assessee, with the appeal succeeding.</description>
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