2015 (8) TMI 1352

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....014, 97 of 2014 - -<br>Income Tax<br>Subhro Kamal Mukherjee (ACJ) And A. V. Chandrashekara, JJ. For the Petitioner : Ameetkumar Deshpande For the Respondent : A. Shankar, V. Chandrashekar, M. Lava JUDGMENT Subhro Kamal Mukherjee (ACJ) These appeals by the revenue are against the judgment and order dated September 30, 2013, passed by the Income-Tax Appellate Tribunal, C Bench, Bengal....

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.... of materials included in composite contracts for executing Turn Key Projects, provisions under Section 194C of the Income- Tax Act, 1961 (for short, 'the Act') 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 are fees for professional and technical services and, therefore, comes within ....

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...., 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 material supplied, no deduction is permissible under Section 194C of the Act. Se....

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....ion of 'work' 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 and Raichur are not professional services, and, therefore, Section 194J is not attract....