1994 (12) TMI 340

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

...., J.- This writ petition is by the Bar Association as well as one of the Advocates questioning the circular issued by the CBDT governing section 194C of the Income-tax Act, 1961 ('the Act') whereby the CBDT purports to rope in several professionals like Advocates, Architects, Chartered Accountants, etc., into the net of section 194C of the Act. 2. It is unnecessary to refer to the co....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....les are stated in S.R.F. Finance Ltd.'s case (supra) and are already considered. Dictionary meaning cannot always dictate the scope of a word. In fact, the words 'carry out any work' in section 194C are the crucial words. The term 'contract' in section 194C(i) has been referred to a particular set of persons for the sake of convenience. 4. Mr. Pandey also referred to a decis....