2011 (5) TMI 822

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....usiness of manufacture and sale of cycles and their spare parts. It was the submission that in the course of survey conducted on the premises of the assessee it was noticed that the packing materials and printing & stationery supplied to the assessee as per the specifications of the assessee company and the logo which are not capable of being used by any other person/party, attracted the provisions of section 194C of the Income Tax Act, 1961. It was the submission that the assessee had not deducted TDS and consequently the Assessing Officer had invoked the provisions of sections 201(1) and 201(1A) of the Act and had raised a demand of 5,57,229/- on the assessee. On appeal, the learned CIT(A) allowed the appeal of the assessee on the ground ....

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....themselves purchased the materials and after doing the requisite manufacturing activities as also subjecting the said material to value added actions, sold the same to the assessee. It was the submission that there was no works contract involved and it was only a sale as was evidenced from the invoices and the purchase orders. He further drew our attention to the decisions of the Hon'ble Delhi High Court in the cases of CIT v. Seagram Manufacturing (P) Ltd., reported in 221 CTR 509, CIT v. Dabur India Ltd., reported in 283 ITR 197 and CIT v. Reebok India Co., reported in 306 ITR 124, wherein the Hon'ble Delhi High Court had categorically given a finding that the supply of corrugated boxes made with some labels printed on the same was a cont....