https://www.taxtmi.com/caselaws?id=446057 HC held for the assessee: the contracts to set up the plant were composite and indivisible, so testing and commissioning formed part of the dominant works contract and did not attract TDS under section 194J. The court applied the principle that a composite contract cannot be artificially bifurcated to treat a component as professional/technical services for higher TDS. Revenue failed to prove any legal basis or facts permitting division of the contracts; therefore higher TDS under section 194J was not chargeable (matter falls within the scope of section 194C). en-us Thu, 16 Nov 2023 00:00:00 +0530 Wed, 18 Feb 2026 16:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446057 HC held for the assessee: the contracts to set up the plant were composite and indivisible, so testing and commissioning formed part of the dominant works contract and did not attract TDS under section 194J. The court applied the principle that a composite contract cannot be artificially bifurcated to treat a component as professional/technical services for higher TDS. Revenue failed to prove any legal basis or facts permitting division of the contracts; therefore higher TDS under section 194J was not chargeable (matter falls within the scope of section 194C). Case-Laws Income Tax Thu, 16 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446057