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    <title>2024 (4) TMI 583 - ITAT MUMBAI</title>
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    <description>Payments to independent vendors for finished goods were treated as purchases on a principal-to-principal basis, not as works contracts. The vendors sourced their own raw materials, manufactured goods to the assessee&#039;s specifications, and transferred property only on delivery. Mere use of the assessee&#039;s logo, packing requirements, or rejection of non-conforming goods did not convert the arrangement into a contract for work. As the assessee did not supply raw materials and the manufacturing activity remained with the vendors, section 194C did not apply. The assessee was therefore not required to deduct tax at source and was not an assessee in default under section 201(1).</description>
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      <description>Payments to independent vendors for finished goods were treated as purchases on a principal-to-principal basis, not as works contracts. The vendors sourced their own raw materials, manufactured goods to the assessee&#039;s specifications, and transferred property only on delivery. Mere use of the assessee&#039;s logo, packing requirements, or rejection of non-conforming goods did not convert the arrangement into a contract for work. As the assessee did not supply raw materials and the manufacturing activity remained with the vendors, section 194C did not apply. The assessee was therefore not required to deduct tax at source and was not an assessee in default under section 201(1).</description>
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