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    <title>2021 (5) TMI 583 - ITAT PUNE</title>
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    <description>A joint venture that merely allocates contract receipts to its members in proportion to the work actually performed is not treated as an independent contractor for TDS purposes. On identical facts in earlier years, the same approach had already been accepted, and no material change in the factual matrix was shown for the year under appeal. As there was no genuine contractor-subcontractor relationship, section 194C was not attracted and the corresponding disallowance under section 40(a)(ia) could not be sustained. The Revenue&#039;s challenge therefore failed.</description>
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      <title>2021 (5) TMI 583 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=407704</link>
      <description>A joint venture that merely allocates contract receipts to its members in proportion to the work actually performed is not treated as an independent contractor for TDS purposes. On identical facts in earlier years, the same approach had already been accepted, and no material change in the factual matrix was shown for the year under appeal. As there was no genuine contractor-subcontractor relationship, section 194C was not attracted and the corresponding disallowance under section 40(a)(ia) could not be sustained. The Revenue&#039;s challenge therefore failed.</description>
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      <pubDate>Mon, 17 May 2021 00:00:00 +0530</pubDate>
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