2012 (6) TMI 234

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....tantial error of law in deleting the demand raised by the concerned Income-tax Authority under Section 201(1) of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') of Rs. 85,20,210/- and interest charge of Rs. 25,64,593/- under Section 210-A of the Act on the ground that the assessee made deduction in accordance with the provisions contained under Section 194-C of the Act. 3. According to the Revenue, the assessee-company had engaged the services of contractors for rendering transportation services for goods and passengers by buses, cars, Sumos, Utility Vans, etc. According to the Revenue, the assessee-Company had not taken possession of those vehicles from the contractor and the responsibility of operating and maintaining of ....

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.... was entered into for carrying various goods and passengers by trailer, utility vans, water tanker, sumos, etc. and thus, it clearly comes within the meaning of 'work'. 6.1 So far the definition of 'rent' as provided in Section 194-I of the Act is concerned, according to the same, 'rent' means any payment, by whatever name called, under any lease, sub-lease, tenancy or any other agreement or arrangement for the use of (either separately or together) any (a)  Land; or (b)  building (include factory building); or (c)  land appurtenant to a building (include factory building); or (d)  machinery; or (e)  plant; or (f)  equipment; or (g)  furniture; or (h)  fittings, whether or not any or all of ....