AJMER ZILA DUGDH UTPADAK SAHKARI SANGH LIMITED,AJMER vs. DC/ACIT CIR-2,AJMER, AJMER

ITA 1419/JPR/2025Status: DisposedITAT Jaipur08 September 2026AY 2018-198 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the payments for packaging materials were not work contracts but contracts for sale. Therefore, TDS under Section 194C was not applicable, and the demand for TDS and interest was deleted.

What were the facts?

The assessee purchased packaging materials through contracts. The AO held these purchases to be work contracts and demanded TDS. The CIT(A) upheld the AO's view but allowed deductions for payments below prescribed limits and excluded GST/VAT from TDS calculation.

What were the issues?

Whether payments for packaging materials constitute a work contract or a contract for sale for the purpose of TDS under Section 194C.

Which sections of the Income-tax Act were involved?

Section 194C,Section 201(1),Section 201(1A)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, JAIPUR BENCHES, “B” BENCH, JAIPUR

Before: SMT. ANNAPURNA GUPTA & SHRI UDAYAN DAS GUPTA

For Appellant: CA (thru V.C)
For Respondent: Smt. Namita Patel, JCIT
Hearing: 02.07.2026Pronounced: 08.09.2026

Per Annapurna Gupta, AM:- The present appeal has been filed by the assessee against the order passed by the Office of the Commissioner of Income Tax, Appeal Addl./JCIT(A), Chennai 04 (hereinafter referred to as “Ld. CIT(A)”), dated 18.09.2025 confirming the order passed by the AO under Section201(1)/201(1A) of the Income Tax Act, 1961 (hereinafter

P a g e | 2 Ajmer Zila DugdhUtpadak Sahkari Sangh Limted referred to as “the Act”), holding the assessee to be an assessee in de fault for non-deduction of tax at source and accordingly raising demand for the tax so not deducted and interest thereon for the delay in the payment of tax.

2.

The assessee was subjected to spot verification/TDS survey and it wa

The order continues below.

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