Associated Cement Co. Ltd. v. CIT

201 ITR 435Supreme Court of India1993#1672 most cited

What is Associated Cement Co. Ltd. v. CIT authority for?

The term "any work" in Section 194C(1) of the Income-tax Act includes contracts for mere labour supply and is not restricted solely to traditional works contracts. Consequently, a payer is liable to deduct tax at source for payments made to contractors for any work, including labour, under this section.

68

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2012 to 2025.

Also referred to as

Associated Cement Co. Ltd. v. CIT · Section 194C · interpretation of 'work' · any work · supply of labour · works contract · TDS on contractors · scope of 194C · payment to contractor · tax deduction at source

Also reported as

67 Taxmann 346

Sections most often in play

Section 139Section 147Section 148Section 153ASection 194CSection 80IASection 132Section 132A

Issues it is cited on

section 80ia(13)section 80ia(4)(i)section 80iabsection 8osection 80ia(4)infrastructure facilitydeduction under section 80iadeduction u/s 80iasection 194csection 80iasection 17section 201(1a)

Judgments citing Associated Cement Co. Ltd. v. CIT

DCIT-1(2)1, MUMBAI., MUMBAI vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LTD, MUMBAI

In the result, all the three appeals filed by the revenue\nare dismissed

ITA 4944/MUM/2024[2017-18]Status: DisposedITAT Mumbai14 Jan 2025AY 2017-18
For Appellant: Mandar VaidyaFor Respondent: Shri Krishna Kumar, Sr. D/R
Section 801A

…oying labour, procures material from a\nthird party. Thus, contracts involving mere labour of the\ncontractor are included in the purview of \"works contract\". We\nfind that the Hon'ble Supreme Court in case of Associated\nCement Co. Ltd. vs. CIT reported in 201 ITR 435 while\ninterpreting the term 'work' u/s 194C of the Act had held that\nwords 'any work' in section 194C(1) of the Act means any\nwork including supply of labour to carry out work and is not\n20\nआयकर अपीलीय अधिकरण\nINCOMETAX APPELLATE TRIBUNAL\nΙ.Τ.Α. No. 4940/Mum/2024\nI.T.A. No. 4942/Mum/2024\nΙ.Τ.Α. No. 4944/Mum/2024\nintended to be confined t…

DCIT-1(2)1, MUMBAI., MUMBAI vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LTD, MUMBAI

In the result In the result, all the three appeals filed by the revenue s filed by the revenue are dismissed

ITA 4942/MUM/2024[2015-16]Status: DisposedITAT Mumbai14 Jan 2025AY 2015-16

Bench: Shri Sandeep Gosain, Hon’Ble & Ms. Padmavathy S., Hon’Ble

For Appellant: Mandar VaidyaFor Respondent: Shri Krishna Kumar, Sr. D/R
Section 801A

…e included in the purview of "works contract". We find that the Hon'ble Supreme Court in case of Associated find that the Hon'ble Supreme Court in case of Associated find that the Hon'ble Supreme Court in case of Associated Cement Co. Ltd. vs. CIT reported in 201 ITR 435 while Cement Co. Ltd. vs. CIT reported in 201 ITR 435 while Cement Co. Ltd. vs. CIT reported in 201 ITR 435 while interpreting the term 'work' u/s 194C of the Act had held that reting the term 'work' u/s 194C of the Act had held that reting the term 'work' u/s 194C of the Act had held that words 'any work' in section 194C(1) of the Act means any…

DCIT-1(2)1, MUMBAI, MUMBAI vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LTD, MUMBAI

In the result In the result, all the three appeals filed by the revenue s filed by the revenue are dismissed

ITA 4940/MUM/2024[2014-15]Status: DisposedITAT Mumbai14 Jan 2025AY 2014-15

Bench: Shri Sandeep Gosain, Hon’Ble & Ms. Padmavathy S., Hon’Ble

For Appellant: Mandar VaidyaFor Respondent: Shri Krishna Kumar, Sr. D/R
Section 801A

…e included in the purview of "works contract". We find that the Hon'ble Supreme Court in case of Associated find that the Hon'ble Supreme Court in case of Associated find that the Hon'ble Supreme Court in case of Associated Cement Co. Ltd. vs. CIT reported in 201 ITR 435 while Cement Co. Ltd. vs. CIT reported in 201 ITR 435 while Cement Co. Ltd. vs. CIT reported in 201 ITR 435 while interpreting the term 'work' u/s 194C of the Act had held that reting the term 'work' u/s 194C of the Act had held that reting the term 'work' u/s 194C of the Act had held that words 'any work' in section 194C(1) of the Act means any…

M/S. SHREE BALAJI ENGICONS PVT. LTD.,BELPAHAR, JHARSUGUDA vs. DCIT, CENTRAL CIRCLE-1(1), SAMBALPUR, SAMBALPUR

In the result, appeals of the assesee in IT(SS)A No

ITA 89/CTK/2023[2017-18]Status: DisposedITAT Cuttack07 Jan 2025AY 2017-18

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

Section 153ASection 194CSection 80Section 801A

…to employing labour, procures material from a third party. Thus, contracts involving mere labour of the contractor are included in the purview of "works contract We find that the Hon'ble Supreme Court in case of Associated Cement Co. Ltd. us. CIT reported in 201 ITR 435 while interpreting the term 'work' u/s 194C of the Act had held that 108 IT(SS)A No.77 & ITA Nos.320,296,88, 141,89,142,13/CTK/2023 &CO No.02/CTK/2023 words any work in section 194C(1) of the Act means any work including supply of labour to carry out work and is not intended to be confined to or restricted to works contract, therefore, a person w…

M/S. SHREE BALAJI ENGICONS PVT. LTD.,BELPAHAR, JHARSUGUDA vs. ACIT, CENTRAL CIRCLE-1(1), SAMBALPUR, SAMBALPUR

In the result, appeals of the assesee in IT(SS)A No

ITA 88/CTK/2023[2016-17]Status: DisposedITAT Cuttack07 Jan 2025AY 2016-17

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

Section 153ASection 194CSection 80Section 801A

…to employing labour, procures material from a third party. Thus, contracts involving mere labour of the contractor are included in the purview of "works contract We find that the Hon'ble Supreme Court in case of Associated Cement Co. Ltd. us. CIT reported in 201 ITR 435 while interpreting the term 'work' u/s 194C of the Act had held that 108 IT(SS)A No.77 & ITA Nos.320,296,88, 141,89,142,13/CTK/2023 &CO No.02/CTK/2023 words any work in section 194C(1) of the Act means any work including supply of labour to carry out work and is not intended to be confined to or restricted to works contract, therefore, a person w…

ASST. CIT, CENTRAL CIRCLE, SAMBALPUR, AAYAKAR BHAWAN, SAMBALPUR vs. SHREE BALAJI ENGICON LIMITED, BELPAHAR RS

In the result, appeals of the assesee in IT(SS)A No

ITA 320/CTK/2023[2011-12]Status: DisposedITAT Cuttack07 Jan 2025AY 2011-12

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

Section 153ASection 194CSection 80Section 801A

…to employing labour, procures material from a third party. Thus, contracts involving mere labour of the contractor are included in the purview of "works contract We find that the Hon'ble Supreme Court in case of Associated Cement Co. Ltd. us. CIT reported in 201 ITR 435 while interpreting the term 'work' u/s 194C of the Act had held that 108 IT(SS)A No.77 & ITA Nos.320,296,88, 141,89,142,13/CTK/2023 &CO No.02/CTK/2023 words any work in section 194C(1) of the Act means any work including supply of labour to carry out work and is not intended to be confined to or restricted to works contract, therefore, a person w…

M/S. SHREE BAALAJI ENGICONS LIMITED,JHARSUGUDA vs. DEPUTY COMMISSIONER OF INCOME TAX ( CENTRAL CIRCLE-1(1), SAMBALPUR

In the result, appeals of the assesee in IT(SS)A No

ITA 296/CTK/2023[2013-14]Status: DisposedITAT Cuttack07 Jan 2025AY 2013-14

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

Section 153ASection 194CSection 80Section 801A

…to employing labour, procures material from a third party. Thus, contracts involving mere labour of the contractor are included in the purview of "works contract We find that the Hon'ble Supreme Court in case of Associated Cement Co. Ltd. us. CIT reported in 201 ITR 435 while interpreting the term 'work' u/s 194C of the Act had held that 108 IT(SS)A No.77 & ITA Nos.320,296,88, 141,89,142,13/CTK/2023 &CO No.02/CTK/2023 words any work in section 194C(1) of the Act means any work including supply of labour to carry out work and is not intended to be confined to or restricted to works contract, therefore, a person w…

ACIT, CENTRAL CIRCLE, SAMBALPUR, SAMBALPUR vs. M/S. SHREE BALAJI ENGICONS PVT. LTD., JHARSUGUDA

In the result, appeals of the assesee in IT(SS)A No

ITA 142/CTK/2023[2017-18]Status: DisposedITAT Cuttack07 Jan 2025AY 2017-18

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

Section 153ASection 194CSection 80Section 801A

…to employing labour, procures material from a third party. Thus, contracts involving mere labour of the contractor are included in the purview of "works contract We find that the Hon'ble Supreme Court in case of Associated Cement Co. Ltd. us. CIT reported in 201 ITR 435 while interpreting the term 'work' u/s 194C of the Act had held that 108 IT(SS)A No.77 & ITA Nos.320,296,88, 141,89,142,13/CTK/2023 &CO No.02/CTK/2023 words any work in section 194C(1) of the Act means any work including supply of labour to carry out work and is not intended to be confined to or restricted to works contract, therefore, a person w…

ACIT, CENTRAL CIRCLE, SAMBALPUR, SAMBALPUR vs. M/S. SHREE BALAJI ENGICONS PVT. LTD., JHARSUGUDA

In the result, appeals of the assesee in IT(SS)A No

ITA 141/CTK/2023[2016-17]Status: DisposedITAT Cuttack07 Jan 2025AY 2016-17

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

Section 153ASection 194CSection 80Section 801A

…to employing labour, procures material from a third party. Thus, contracts involving mere labour of the contractor are included in the purview of "works contract We find that the Hon'ble Supreme Court in case of Associated Cement Co. Ltd. us. CIT reported in 201 ITR 435 while interpreting the term 'work' u/s 194C of the Act had held that 108 IT(SS)A No.77 & ITA Nos.320,296,88, 141,89,142,13/CTK/2023 &CO No.02/CTK/2023 words any work in section 194C(1) of the Act means any work including supply of labour to carry out work and is not intended to be confined to or restricted to works contract, therefore, a person w…

ACIT, CENTRAL CIRCLE, SAMBALPUR, SAMBALPUR vs. M/S. SHREE BALAJI ENGICONS PVT. LTD., JHARSUGUDA

In the result, appeals of the assesee in IT(SS)A No

ITA 13/CTK/2023[2018-19]Status: DisposedITAT Cuttack07 Jan 2025AY 2018-19

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

Section 153ASection 194CSection 80Section 801A

…to employing labour, procures material from a third party. Thus, contracts involving mere labour of the contractor are included in the purview of "works contract We find that the Hon'ble Supreme Court in case of Associated Cement Co. Ltd. us. CIT reported in 201 ITR 435 while interpreting the term 'work' u/s 194C of the Act had held that 108 IT(SS)A No.77 & ITA Nos.320,296,88, 141,89,142,13/CTK/2023 &CO No.02/CTK/2023 words any work in section 194C(1) of the Act means any work including supply of labour to carry out work and is not intended to be confined to or restricted to works contract, therefore, a person w…

THE JOINT COMMISSIONER OF INCOME TAX (TDS), DEHRADUN vs. THE DIRECTOR, HIGHER EDUCATION, NANITAL

In the result, all the Revenue’s appeals are dismissed

ITA 18/DDN/2020[2014-2015]Status: DisposedITAT Dehradun27 Jul 2023AY 2014-2015

Bench: The Hon'Ble Itat. 3. That The Ld. Cit(Appeals), Haldwani Be Set Aside That Of The Ao Be Restored.”

For Appellant: NoneFor Respondent: Smt. Poonam Sharma, Addl. CIT DR
Section 201Section 271Section 271C

…the assessee, the position was corrected" Further, reliance can also be placed on the decisions in the case of Birla Cement Works vs. C.B.D.T. & Others 248 ITR 201 page 217 and Associated Cement Co. ltd. Vs. CIT (1993) 111 CTR 165 (1993) 67 Taxman 346, (1993) 201 ITR 435, 439 (SC) wherein it has been observed that the following conditions have to be satisfied for attracting section 194(C) No.1 : there must be a contract between the person responsible for making payment & the contractors. In the present case of the assessee, as confirmed by the appellant, there was no such agreements or contracts with the executin…

ADDL.CIT, SPECIAL RANGE-1, NEW DELHI vs. DINESH KUMAR MATHUR, NEW DELHI

In the result, the appeal of the Revenue is dismissed

ITA 1016/DEL/2019[2008-09]Status: DisposedITAT Delhi23 Dec 2022AY 2008-09

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

For Appellant: Shri R.B. Mathur, CAFor Respondent: Shri Kumar Pranav, Sr.DR
Section 143(3)Section 147Section 206ASection 260ASection 40

…Alankar Creations and no separation of receipt from M/s Alankar Creations into reimbursement and management charges. AO disallowed an amount of Rs.3,91,66,460/- relying upon the judgment of Hon’ble Supreme Court in the case of Associated Cement Company v CIT 201 ITR 435 (SC) wherein it was held that person responsible for deduction for tax has to deduct tax on the entire sum paid or credited and not merely from the income component of the same. On appeal CIT(A) held that amount of 2% required to be deducted by the buyer out of the sum credited to the account or paid to the contractor has to be confined on his in…

M/S ABDUL GAFFAR HAZI HASSAN,BILASPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1), BILASPUR

In the result, the appeal of assessee is allowed

ITA 289/RPR/2017[2013-14]Status: DisposedITAT Raipur21 Sept 2022AY 2013-14

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita No.289/Rpr/2017 (ननधाारण वषा / Assessment Year :2013-2014) M/S Abdul Gaffar Hazi Hassan, Vs Dcit, Circle-1(1), Bilaspur Bukhari Service Station, Link Road Bilaspur(C.G.)-495001 Pan No. : Aajfa 2350 G (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: NoneFor Respondent: Shri G.N.Singh, Sr. DR
Section 40

…considers just by relaxing the rigour of the law. It is a beneficial power for proper administration of fiscal law to avoid undue hardship. Thus, when the Board sought to apply its own interpretation of the Court's ruling in Associated Cement Companies Case, 201 ITR 435, SC, and chose to enforce tax deduction at source under Section 194 C to transport contracts through Circular No. 681 dated March 8 1994, a Full Bench of the Supreme Court pronounced the law on the subject and declared the Circular invalid pointing out that the Court's ruling in Associated Cements case was not correctly understood by the CBDT. He…

SHREE SIDDHI VINAYAK INDUCTIONS PVT. LTD.,JAIPUR vs. DCIT, CENTRAL CIRCLE-3, JAIPUR

In the result ITA NO. 01/JPR/2021 for A

ITA 1/JPR/2021[2015-16]Status: DisposedITAT Jaipur29 Aug 2022AY 2015-16
For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. P. R. Meena (PCIT)
Section 143(3)Section 145(3)Section 36(1)(va)Section 40Section 43B

…was not claimed in Profit & Loss account, the same is to be treated as Revenue receipt and provisions of section 43B are applicable to the case. Ld. AO relied on the decision of Hon’ble Supreme Court in the case of Associate Cement Company Ltd. vs CIT (1993) 201 ITR 435 and Apex Court decision in the case of Chowringhee Sales Bureau (1973) 87 ITR 542 in AY 2012-13 and in other two assessment years the ld. AO has relied upon the judgment of hon’ble Bench in the case of SVG Express Services which was relied upon by ld. CIT(A) in AY 2012-13 while dismissing the appeal of the assessee . In this regard, at the outse…

M/S SHRI SIDDHI VINAYAK INDUCTION P. LTD.,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, JAIPUR

In the result ITA NO. 01/JPR/2021 for A

ITA 279/JPR/2019[2014-15]Status: DisposedITAT Jaipur29 Aug 2022AY 2014-15
For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. P. R. Meena (PCIT)
Section 143(3)Section 145(3)Section 36(1)(va)Section 40Section 43B

…was not claimed in Profit & Loss account, the same is to be treated as Revenue receipt and provisions of section 43B are applicable to the case. Ld. AO relied on the decision of Hon’ble Supreme Court in the case of Associate Cement Company Ltd. vs CIT (1993) 201 ITR 435 and Apex Court decision in the case of Chowringhee Sales Bureau (1973) 87 ITR 542 in AY 2012-13 and in other two assessment years the ld. AO has relied upon the judgment of hon’ble Bench in the case of SVG Express Services which was relied upon by ld. CIT(A) in AY 2012-13 while dismissing the appeal of the assessee . In this regard, at the outse…

SHREE SIDDHI VINAYAK INDUCTION PVT. LTD.,JAIPUR vs. DCIT, JAIPUR

In the result ITA NO. 01/JPR/2021 for A

ITA 116/JPR/2017[2012-13]Status: DisposedITAT Jaipur29 Aug 2022AY 2012-13
For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. P. R. Meena (PCIT)
Section 143(3)Section 145(3)Section 36(1)(va)Section 40Section 43B

…was not claimed in Profit & Loss account, the same is to be treated as Revenue receipt and provisions of section 43B are applicable to the case. Ld. AO relied on the decision of Hon’ble Supreme Court in the case of Associate Cement Company Ltd. vs CIT (1993) 201 ITR 435 and Apex Court decision in the case of Chowringhee Sales Bureau (1973) 87 ITR 542 in AY 2012-13 and in other two assessment years the ld. AO has relied upon the judgment of hon’ble Bench in the case of SVG Express Services which was relied upon by ld. CIT(A) in AY 2012-13 while dismissing the appeal of the assessee . In this regard, at the outse…

SHREE BALAJI ENGICONS PVT. LTD,JHARSUGUDA vs. PRINCIPAL CIT, SAMBALPUR

In the result, appeal of the assessee in ITA No

ITA 195/CTK/2019[204-15]Status: DisposedITAT Cuttack15 Dec 2021

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am आयकर अपीऱ सं./Ita Nos.193/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) M/S Rawats-Balaji(Jv), Vs Pr.Cit, Sambalpur At/Po-Belpahar(Rs), Dist : Jharsuguda Pan No. : Aabar 9061 J Tan No. : Bbnr01647 C & आयकर अपीऱ सं./Ita Nos.194/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) M/S Sbepl-Gril(Jv), Vs Pr.Cit, Sambalpur At/Po-Belpahar(Rs), Dist : Jharsuguda Pan No. : Aafas 2639 R Tan No. : Bbns04348 B & आयकर अपीऱ सं./Ita Nos.195/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) Shree Balaji Engicons Pvt Ltd Vs Pr.Cit, Sambalpur At/Po-Belpahar(Rs), Dist : Jharsuguda Pan No. : Aagcs 4292 P Tan No. : Bbns00091 A (अऩीलाथी /Appellant) (प्रत्यथी / Respondent) .. ननधाारिती की ओर से /Assessee By : Shri Satyanarayan Agarwal, Ar िाजस्व की ओर से /Revenue By : Shri M.K.Gautam, Citdr सुनवाई की तािीख / Date Of Hearing : 26/10/2021 घोषणा की तािीख/Date Of Pronouncement : 23/12/2021 आदेश / O R D E R Per Bench: These Three Appeals Have Been Filed By Three Different Assessees Against The Order Passed By The Pr.Cit, Sambalpur, U/S.263 Of The Act, All Dated 30.03.2019 For The Assessment Year 2014-2015. 2

For Appellant: Shri Satyanarayan Agarwal, ARFor Respondent: Shri M.K.Gautam, CITDR
Section 143(3)Section 14ASection 263Section 80I

…o employing labour, procures material from a third party. Thus, contracts involving mere labour of the contractor are included in the purview of "works contract". We find that the Hon'ble Supreme Court in case of Associated Cement Co. Ltd. vs. CIT reported in 201 ITR 435 while interpreting the term 'work' u/s 194C of the Act had held that words any work' in section 194C{l) of the Act means any work including supply of labour to carry out work and is not intended to be confined to or restricted to works contract, therefore, a person who credits to the account of or pays to a contractor any sum payable on behalf of…

M/S- SBEP-GRIL(JOINT VENTURE),JHARSUGUDA vs. PRINCIPAL CIT, SAMBALPUR

In the result, appeal of the assessee in ITA No

ITA 194/CTK/2019[2014-15]Status: DisposedITAT Cuttack15 Dec 2021AY 2014-15

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am आयकर अपीऱ सं./Ita Nos.193/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) M/S Rawats-Balaji(Jv), Vs Pr.Cit, Sambalpur At/Po-Belpahar(Rs), Dist : Jharsuguda Pan No. : Aabar 9061 J Tan No. : Bbnr01647 C & आयकर अपीऱ सं./Ita Nos.194/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) M/S Sbepl-Gril(Jv), Vs Pr.Cit, Sambalpur At/Po-Belpahar(Rs), Dist : Jharsuguda Pan No. : Aafas 2639 R Tan No. : Bbns04348 B & आयकर अपीऱ सं./Ita Nos.195/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) Shree Balaji Engicons Pvt Ltd Vs Pr.Cit, Sambalpur At/Po-Belpahar(Rs), Dist : Jharsuguda Pan No. : Aagcs 4292 P Tan No. : Bbns00091 A (अऩीलाथी /Appellant) (प्रत्यथी / Respondent) .. ननधाारिती की ओर से /Assessee By : Shri Satyanarayan Agarwal, Ar िाजस्व की ओर से /Revenue By : Shri M.K.Gautam, Citdr सुनवाई की तािीख / Date Of Hearing : 26/10/2021 घोषणा की तािीख/Date Of Pronouncement : 23/12/2021 आदेश / O R D E R Per Bench: These Three Appeals Have Been Filed By Three Different Assessees Against The Order Passed By The Pr.Cit, Sambalpur, U/S.263 Of The Act, All Dated 30.03.2019 For The Assessment Year 2014-2015. 2

For Appellant: Shri Satyanarayan Agarwal, ARFor Respondent: Shri M.K.Gautam, CITDR
Section 143(3)Section 14ASection 263Section 80I

…o employing labour, procures material from a third party. Thus, contracts involving mere labour of the contractor are included in the purview of "works contract". We find that the Hon'ble Supreme Court in case of Associated Cement Co. Ltd. vs. CIT reported in 201 ITR 435 while interpreting the term 'work' u/s 194C of the Act had held that words any work' in section 194C{l) of the Act means any work including supply of labour to carry out work and is not intended to be confined to or restricted to works contract, therefore, a person who credits to the account of or pays to a contractor any sum payable on behalf of…

M/S- RAWAT BALAJI (JOINT VENTURE),JHARSUGUDA vs. PRILNCIPAL, CIT, SAMBALPUR

In the result, appeal of the assessee in ITA No

ITA 193/CTK/2019[204-15]Status: DisposedITAT Cuttack15 Dec 2021

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am आयकर अपीऱ सं./Ita Nos.193/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) M/S Rawats-Balaji(Jv), Vs Pr.Cit, Sambalpur At/Po-Belpahar(Rs), Dist : Jharsuguda Pan No. : Aabar 9061 J Tan No. : Bbnr01647 C & आयकर अपीऱ सं./Ita Nos.194/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) M/S Sbepl-Gril(Jv), Vs Pr.Cit, Sambalpur At/Po-Belpahar(Rs), Dist : Jharsuguda Pan No. : Aafas 2639 R Tan No. : Bbns04348 B & आयकर अपीऱ सं./Ita Nos.195/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) Shree Balaji Engicons Pvt Ltd Vs Pr.Cit, Sambalpur At/Po-Belpahar(Rs), Dist : Jharsuguda Pan No. : Aagcs 4292 P Tan No. : Bbns00091 A (अऩीलाथी /Appellant) (प्रत्यथी / Respondent) .. ननधाारिती की ओर से /Assessee By : Shri Satyanarayan Agarwal, Ar िाजस्व की ओर से /Revenue By : Shri M.K.Gautam, Citdr सुनवाई की तािीख / Date Of Hearing : 26/10/2021 घोषणा की तािीख/Date Of Pronouncement : 23/12/2021 आदेश / O R D E R Per Bench: These Three Appeals Have Been Filed By Three Different Assessees Against The Order Passed By The Pr.Cit, Sambalpur, U/S.263 Of The Act, All Dated 30.03.2019 For The Assessment Year 2014-2015. 2

For Appellant: Shri Satyanarayan Agarwal, ARFor Respondent: Shri M.K.Gautam, CITDR
Section 143(3)Section 14ASection 263Section 80I

…o employing labour, procures material from a third party. Thus, contracts involving mere labour of the contractor are included in the purview of "works contract". We find that the Hon'ble Supreme Court in case of Associated Cement Co. Ltd. vs. CIT reported in 201 ITR 435 while interpreting the term 'work' u/s 194C of the Act had held that words any work' in section 194C{l) of the Act means any work including supply of labour to carry out work and is not intended to be confined to or restricted to works contract, therefore, a person who credits to the account of or pays to a contractor any sum payable on behalf of…

BANGALORE METRO RAIL CORPORATION vs. DEPUTY COMMISSIONER OF INCOME TAX

The appeals are allowed in part

ITA/673/2016HC Karnataka28 Sept 2021

Bench: S.SUJATHA,RAVI V HOSMANI

Section 12ASection 194JSection 260Section 260A

…IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 28TH DAY OF SEPTEMBER, 2021 PRESENT THE HON’BLE MRS.JUSTICE S.SUJATHA AND THE HON’BLE MR. JUSTICE RAVI V. HOSMANI I.T.A.No.673/2016 C/W I.T.A.No.671/2016 & I.T.A.No.672/2016 IN I.T.A.No.673/2016: BETWEEN : BANGALORE METRO RAIL CORPORATION LIMITED, 3RD FLOOR, BMTC COMPLEX, K.H.ROAD, SHANTI NAGAR, BENGALURU-560027 ...APPELLANT (BY SRI A.SHANKAR, SENIOR COUNSEL A/W SRI BHAIRAV KUTTAIAH, ADV.) AND : DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-16(1) 4TH FLOOR, HMT BHAVAN, BENGALURU-560032…

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Associated Cement Co. Ltd. v. CIT (201 ITR 435) — Cited in 68 Judgments | BharatTax