https://www.taxtmi.com/caselaws?id=16333 The Karnataka HC ruled that transport contractors were not covered under section 194C for TDS purposes prior to July 1, 1995. The court held that "work" in section 194C refers to physical labor activities, not mere transportation of goods by common carriers. The Department's interpretation excluding transport contracts from 1973-1994 was valid. Explanation III inserted by Finance Act 1995, which specifically included transport contracts, was substantive rather than explanatory and applied prospectively from July 1, 1995, not retroactively to April 1, 1994. CBDT Circular No. 666 was deemed invalid for the pre-1995 period. en-us Thu, 14 Jan 1999 00:00:00 +0530 Tue, 11 Feb 2025 11:21:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=16333 The Karnataka HC ruled that transport contractors were not covered under section 194C for TDS purposes prior to July 1, 1995. The court held that "work" in section 194C refers to physical labor activities, not mere transportation of goods by common carriers. The Department's interpretation excluding transport contracts from 1973-1994 was valid. Explanation III inserted by Finance Act 1995, which specifically included transport contracts, was substantive rather than explanatory and applied prospectively from July 1, 1995, not retroactively to April 1, 1994. CBDT Circular No. 666 was deemed invalid for the pre-1995 period. Case-Laws Income Tax Thu, 14 Jan 1999 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=16333