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    <title>2021 (4) TMI 1049 - KARNATAKA HIGH COURT</title>
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    <description>Software engineers engaged in software development were treated as &quot;workmen&quot; for section 80JJAA because technical staff fall within the wider industrial law definition unless mainly managerial or supervisory; the deduction was also allowed where the 300-day employment condition was met through continuous service spanning successive years. Lease rentals for motor vehicles were not held to attract TDS under section 194C or section 194I because the arrangement merely made vehicles available and did not involve work, transport service, or rent in the statutory sense; disallowance under section 40(a)(ia) therefore failed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=406933</link>
      <description>Software engineers engaged in software development were treated as &quot;workmen&quot; for section 80JJAA because technical staff fall within the wider industrial law definition unless mainly managerial or supervisory; the deduction was also allowed where the 300-day employment condition was met through continuous service spanning successive years. Lease rentals for motor vehicles were not held to attract TDS under section 194C or section 194I because the arrangement merely made vehicles available and did not involve work, transport service, or rent in the statutory sense; disallowance under section 40(a)(ia) therefore failed.</description>
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