Assessee's Payments to Harvesters and Transporters Trigger TDS Deduction Duty u/s 194C; Disallowance Upheld.

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....TDS u/s 194C - payment to harvesters/transporters - the payments made by the assessee were not made on behalf of the farmers, in such scenario, there is a strict relationship between the assessee and the contractor/transporter as that of the contractor and the contractee and in such circumstances, the assessee was under the legal obligation to deduct TDS u/s 194C and since this legal obligation was not fulfilled by the assessee, therefore, disallowance u/s. 40(a)(ia) as confirmed by CIT (Appeals) is hereby sustained. - AT....