2015 (8) TMI 1042

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....of 2014, 84 of 2014, 85 of 2014, 86 of 2014, 88 of 2014, 89 of 2014, 91 of 2014, 98 of 2014, Income Tax Appeal No. 75 of 2014 - -<br>Income Tax<br>Subhro Kamal Mukherjee, ACJ And Anand Byrareddy, JJ. For the Appellant : Mr. Y. V. Raviraj, Adv. For the Respondent : Mr. Anoop G. Deshpande, Adv. JUDGMENT These appeals by the revenue are against the judgment and order dated September 30, 2....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....nvolved in these appeals is if on the payment made against the supply of materials included in composite contracts for executing Turn Key Projects, provisions under Section 194C of the Income-Tax Act, 1961 (for short, &#39;the Act&#39;) would attract or not. 5. The other issue is if payments made by the assessee to Bellary Computers and IT Solutions, Bellary, towards Bill Management Services ar....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

..... We are, also, of the opinion that the clauses of the contract particularly, clause 3.5 of the contract agreement, make it clear that three separate contracts have been entered into, but all the separate contracts were integral parts of a composite contract on single sale responsible basis. The invoices raised on the basis of the said composite contract separately mentioning the value of the mate....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....a person other than the customer, the same would not fall within the definition of &#39;work&#39; under Section 194C of the Act. 9. Now, we shall deal with the second issue. If the provisions of Section 194J or Section 194C would apply in respect of payments made by an assessee towards Bill Management Services. The services rendered by the agencies engaged by the assessees at Hospet, Bellary an....