Disallowance u/s 40(a)(ia): JV for government contracts not a subcontract with its constituents u/s 194C.

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....Disallowance u/s 40(a)(ia) - TDS u/s 194C - There is no sub-contract between JV and the constituents and since the JV has been formed only to procure contract works from the Government and the contract is being executed by the constituent partners in their sharing ratio 60:40 as per the terms of JV, it cannot be said that the JV is a contractor and its constituents are sub-contractors - AT....