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2007 (7) TMI 663
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....the Supreme Court has cited with approval a passage from R.B. Jodha Mal Kuthiala v. CIT [1971] 82 ITR 570 (SC) where it has been observed that provisions of a section of the Income Tax Act should not be interpreted in such a manner that to make it capable of being an instrument of oppression. 2. The Revenue is aggrieved by an order dated 20th October, 2006 passed by the Income Tax Appellate Tri....
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....t it was not required to deduct tax at source under section 194 I of the Act in respect of the fixture and furniture charges . There is no dispute about the fact that the assessee did deduct tax at source under section 194C of the Act in respect of these charges. On this basis, both the Commissioner as well as the Tribunal came to the conclusion that the Assessee had shown reasonable cause as r....