TDS Disallowance u/s 40(a)(ia): Clarification on Sub-Contractor Classification and Risk Transfer in Contracts.

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....Dis-allowance u/s 40(a)(ia) - TDS u/s 194C - Until and unless risk and responsibility of the contract undertaken by the assessee is shifted to the sub-contractors, it cannot be held that these persons are the sub-contractors of the assessee. - AT....