Associated Cement Co. Ltd. v. CIT

201 ITR 435Supreme Court of India1993#1671 most cited

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

The phrase 'any work' in Section 194C(1) of the Income Tax Act includes the supply of labour to carry out work, and is not confined to traditional works contracts.

68

judgments rely on this decision, according to BharatTax’s citation analysis of 366,459 Indian tax judgments — from 2012 to 2025.

Also referred to as

Associated Cement Co. Ltd. v. CIT · Section 194C · TDS on payments to contractors · definition of work · supply of labour · works contract

Also reported as

67 Taxmann 346

Sections most often in play

Section 139Section 147Section 148Section 153ASection 194CSection 80IASection 132Section 132A
Read the full judgment

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, Circle-12(2), Kolkata vs. M/S. Simplex Infrastructures Ltd., Kolkata

In the result, Ground No. 1 of the revenue is dismissed

ITA 141/KOL/2015[2006-2007]Status: DisposedITAT Kolkata25 Oct 2017AY 2006-2007

Bench: Sri N.V. Vasudevan & Sri J. Sudhakar Reddy]

Section 250Section 80Section 80ISection 91

…r, procures material from a third party. Thus, contracts involving mere labour of the contractor are included in the purview of "works contract". Further, attention is invited to the judgment of the Supreme Court in case of Associated Cement Co. Ltd. vs. CIT [201 ITR 435], wherein the Hon'ble Court while interpreting the term 'work' u/s 194C held that "Words `any work' in sub-s. (1) of s. 194C means any work including supply of labour to carry out work and is not intended to be confined to or restricted to 20 I.T.A. No. 140/Kol/2015 Assessment Year: 2005-06 & I.T.A. No. 141/Kol/2015 Assessment Year: 2006-07 M…

DCIT, Circle-12(2), Kolkata vs. M/S. Simplex Infrastructures Ltd., Kolkata

In the result, Ground No. 1 of the revenue is dismissed

ITA 140/KOL/2015[2005-2006]Status: DisposedITAT Kolkata25 Oct 2017AY 2005-2006

Bench: Sri N.V. Vasudevan & Sri J. Sudhakar Reddy]

Section 250Section 80Section 80ISection 91

…r, procures material from a third party. Thus, contracts involving mere labour of the contractor are included in the purview of "works contract". Further, attention is invited to the judgment of the Supreme Court in case of Associated Cement Co. Ltd. vs. CIT [201 ITR 435], wherein the Hon'ble Court while interpreting the term 'work' u/s 194C held that "Words `any work' in sub-s. (1) of s. 194C means any work including supply of labour to carry out work and is not intended to be confined to or restricted to 20 I.T.A. No. 140/Kol/2015 Assessment Year: 2005-06 & I.T.A. No. 141/Kol/2015 Assessment Year: 2006-07 M…

Asst CIT (TDS) 1(3), Mumbai vs. Mumbai Port Trust, Mumbai

ITA 463/MUM/2015[2011-12]Status: DisposedITAT Mumbai11 Oct 2017AY 2011-12
For Appellant: Shri Hari S. RahejaFor Respondent: Shri Saurabh Kumar Rai-DR
Section 133ASection 194Section 194CSection 194JSection 201Section 254(1)Section 316

…ough Capital Tourist Taxi Operators,the FAA held that claim made by assessee was supported by bills and terms of contract ,that the contracts were not for having vehicles.He referred to cases of Kandla Port Trust(ITA/451/Rjt/2012)and Associated Cement Co.Ltd.(201 ITR 435)and allowed the appeal filed by the assessee . 4.During the course of hearing before us,the Departmental Representative (DR) supported the order of the AO and stated that contracts entered into by the assessee were for providing technical services, or for hiring of vehicles,that the assessee should have deducted tax as per provisions of Section…

DCIT (TDS) 1(3), Mumbai vs. Mumbai Port Trust, Mumbai

ITA 3930/MUM/2015[2012-13]Status: DisposedITAT Mumbai11 Oct 2017AY 2012-13
For Appellant: Shri Hari S. RahejaFor Respondent: Shri Saurabh Kumar Rai-DR
Section 133ASection 194Section 194CSection 194JSection 201Section 254(1)Section 316

…ough Capital Tourist Taxi Operators,the FAA held that claim made by assessee was supported by bills and terms of contract ,that the contracts were not for having vehicles.He referred to cases of Kandla Port Trust(ITA/451/Rjt/2012)and Associated Cement Co.Ltd.(201 ITR 435)and allowed the appeal filed by the assessee . 4.During the course of hearing before us,the Departmental Representative (DR) supported the order of the AO and stated that contracts entered into by the assessee were for providing technical services, or for hiring of vehicles,that the assessee should have deducted tax as per provisions of Section…

ITO (TDS) 2(3), Mumbai vs. Mumbai Port Trust & Tender Branch, Mumbai

ITA 3168/MUM/2014[2010-11]Status: DisposedITAT Mumbai11 Oct 2017AY 2010-11
For Appellant: Shri Hari S. RahejaFor Respondent: Shri Saurabh Kumar Rai-DR
Section 133ASection 194Section 194CSection 194JSection 201Section 254(1)Section 316

…ough Capital Tourist Taxi Operators,the FAA held that claim made by assessee was supported by bills and terms of contract ,that the contracts were not for having vehicles.He referred to cases of Kandla Port Trust(ITA/451/Rjt/2012)and Associated Cement Co.Ltd.(201 ITR 435)and allowed the appeal filed by the assessee . 4.During the course of hearing before us,the Departmental Representative (DR) supported the order of the AO and stated that contracts entered into by the assessee were for providing technical services, or for hiring of vehicles,that the assessee should have deducted tax as per provisions of Section…

ITO (TDS) 2(3), Mumbai vs. Mumbai Port Trust & Tender Branch, Mumbai

ITA 3167/MUM/2014[2009-10]Status: DisposedITAT Mumbai11 Oct 2017AY 2009-10
For Appellant: Shri Hari S. RahejaFor Respondent: Shri Saurabh Kumar Rai-DR
Section 133ASection 194Section 194CSection 194JSection 201Section 254(1)Section 316

…ough Capital Tourist Taxi Operators,the FAA held that claim made by assessee was supported by bills and terms of contract ,that the contracts were not for having vehicles.He referred to cases of Kandla Port Trust(ITA/451/Rjt/2012)and Associated Cement Co.Ltd.(201 ITR 435)and allowed the appeal filed by the assessee . 4.During the course of hearing before us,the Departmental Representative (DR) supported the order of the AO and stated that contracts entered into by the assessee were for providing technical services, or for hiring of vehicles,that the assessee should have deducted tax as per provisions of Section…

ITO (TDS) 2(3), Mumbai vs. Mumbai Port Trust & Tender Branch, Mumbai

ITA 3166/MUM/2014[2008-09]Status: DisposedITAT Mumbai11 Oct 2017AY 2008-09
For Appellant: Shri Hari S. RahejaFor Respondent: Shri Saurabh Kumar Rai-DR
Section 133ASection 194Section 194CSection 194JSection 201Section 254(1)Section 316

…ough Capital Tourist Taxi Operators,the FAA held that claim made by assessee was supported by bills and terms of contract ,that the contracts were not for having vehicles.He referred to cases of Kandla Port Trust(ITA/451/Rjt/2012)and Associated Cement Co.Ltd.(201 ITR 435)and allowed the appeal filed by the assessee . 4.During the course of hearing before us,the Departmental Representative (DR) supported the order of the AO and stated that contracts entered into by the assessee were for providing technical services, or for hiring of vehicles,that the assessee should have deducted tax as per provisions of Section…

ITO (OSD) TDS-3(1), Mumbai vs. Vodafone Essar Ld, Mumbai

Appeal stands dismissed

ITA 157/MUM/2010[2009-10]Status: DisposedITAT Mumbai02 Aug 2017AY 2009-10

Bench: S/Shri Rajendra & Saktijit Deyआयकर आयकर अपील अपील संसंसंसं/ Ita No. 155-157/Mum/2010: आयकर आयकर अपील अपील िनधा"रण वष" वष"/Assessment Year:2007-08 To 2009-10 िनधा"रण िनधा"रण िनधा"रण वष" वष" Income Tax Officer (Osd)-Tds-3(1) M/S. Vodafone Essar Ltd. 10Th Floor, Smt. K.G. Mittal Ayurvedic Penninsula Corporate Park Hospital Building, Vs. Ganpatrao Kadam Marg, Lower Parel Charni Road (W), Mumbai-400 002. Mumbai-400 013. Pan:Aaacu 5332 B (अपीलाथ" /Appellant) (""यथ" / Respondent) Revenue By: Shri B.S. Bisht Assessee By: Shri P.J. Pardiwala & Sh.Vivek Parekh सुनवाई क" तारीख / Date Of Hearing: 28/07/2017 घोषणा क" तारीख / Date Of Pronouncement: 02.08.2017 आयकर अिधिनयम अिधिनयम,1961 क" क" धारा धारा 254(1)केकेकेके अ"तग"त अ"तग"त आदेश आदेश आयकर आयकर आयकर अिधिनयम अिधिनयम क" क" धारा धारा अ"तग"त अ"तग"त आदेश आदेश Order U/S.254(1)Of The Income-Tax Act,1961(Act) लेखा सद"य सद"य, राजे"" राजे"" केकेकेके अनुसार अनुसार/ Per Rajendra A.M.- लेखा लेखा लेखा सद"य सद"य राजे"" राजे"" अनुसार अनुसार Challenging The Orders,Dated 18.03.2009,Of Cit(A)-14,Mumbai The Assessee Has Filed The Appeals For The Above Mentioned Assessment Years(Ay.S).Assessee Company Is Engaged In The Business Of Providing Cellular Services In The Region Of Mumbai & Kalyan Circles. As The Issues Involved In Both The Appeals Deal With The Identical Questions,Therefore,We Are Adjudicating Them Together.

For Appellant: Shri P.J. Pardiwala & Sh.Vivek ParekhFor Respondent: Shri B.S. Bisht
Section 133ASection 194Section 194CSection 194JSection 201Section 201(1)Section 254(1)

…of advertising, (ii) in any other case two per cent., of such sum as income-tax on income comprised therein : The term ‘work’has been defined in explanation III to section 194C of the Act.It is an inclusive definition.In the case of Associated Cement Co Ltd (201 ITR 435),the Hon’ble Supreme Court has defined the word work as under: “No ambiguity is found in the language employed in the sub-section. What is contained in the sub-section, as appears from its plain reading and analysis, admits of the following formulations: (1) A contract may be entered into between the contractor and any of the organisations specif…

M/S Ac Cargo Management P.Ltd, Cochin vs. The ITO, Cochin

In the result, the appeal of the assessee is partly allowed

ITA 320/COCH/2013[2007-08]Status: DisposedITAT Cochin23 Mar 2017AY 2007-08

Bench: Shri Abraham P. George & Shri George George. K.] आयकर अपील सं./I.T.A. No. 320/Coch/2013. िनधा"रण वष" /Assessment Year : 2007-2008. Vs. M/S. Ac Cargo Management The Income Tax Officer, Pvt. Ltd, Ward 1(1) 1St Floor, Chacko Chambers, Kochi Civil Lines Road, Palarivattom, Kochi 682 025. [Pan Aaeca 2206K] (अपीलाथ" अपीलाथ" अपीलाथ"/Appellant) अपीलाथ" (ू"यथ" ू"यथ" ू"यथ"/Respondent) ू"यथ"

For Appellant: Shri. R. Krishnan, C.A
Section 194Section 194CSection 194ISection 40

…by virtue of judgments of Hon’ble Jurisdictional High Court in the case of CIT vs. PVS Memorial Hospital Ltd 380 ITR 284, CBDT vs. Cochin Goods Transport Association 236 ITR 993 and that of Hon’ble Apex Court in the case of Associated Cement Co. Ltd vs. CIT 201 ITR 435, payments made by the assessee to contractors were liable for TDS and the assessee had failed to effect such deductions. According to him, lower authorities were justified in applying Section 40(a)(ia) of the Act. :- 6 -: 7. We have considered the rival contentions and perused the orders of the authorities below. It would be apposite to have l…

D.C.I.T., Circle-12, Kolkata vs. M/S Simplex Infrastructure Ltd., Kolkata

In the result, Revenue’s appeal stands dismissed

ITA 2777/KOL/2013[2007-2008]Status: DisposedITAT Kolkata10 Mar 2017AY 2007-2008

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmedassessment Year :2007-08

Section 143(3)Section 80Section 80I

…r, procures material from a third party. Thus, contracts involving mere labour of the contractor are included in the purview of "works contract". Further, attention is invited to the judgment of the Supreme Court in case of Associated Cement Co. Ltd. vs. CIT [201 ITR 435], wherein the Hon'ble Court while interpreting the term 'work' u/s 194C held that “Words `any work' in sub-s. (1) of s. 194C 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 ITA No.2777/Kol/2013 A.Y. 200…

I.T.O WD - 8(4), Kolkata vs. M/S Spml Infra Ltd, Kolkata

In the result, to sum up

ITA 2286/KOL/2013[2005-06]Status: DisposedITAT Kolkata08 Mar 2017AY 2005-06

Bench: Shri M. Balaganesh, Am & Shri Partha Sarathi Chaudhury, Jm]

For Appellant: Shri Ravi Tulsiyan, FCAFor Respondent: Shri Arup Kr. Sinha, CIT
Section 143(3)Section 80I

…ition 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’. (D) The Hon’ble Supreme Court in the case of Associated Cement Co. Ltd vs CIT reported in 201 ITR 435 (SC) had interpreted the term ‘work’ as below:- No ambiguity is found in the language employed in section 194C(1 ). On plain reading of said section, what is contained in the sub-section, admits of the following formulations: (1) A contract may be entered into between the contractor and any of the organisations specified in the sub-section. (2) C…

M/S Smpl Infra Ltd ( Eastwhile M/S Subhas Projects & Marketing Ltd), Kolkata vs. D.C.I.T CC - Xxviii, Kolkata

In the result, to sum up

ITA 2035/KOL/2013[2008-09]Status: DisposedITAT Kolkata08 Mar 2017AY 2008-09

Bench: Shri M. Balaganesh, Am & Shri Partha Sarathi Chaudhury, Jm]

For Appellant: Shri Ravi Tulsiyan, FCAFor Respondent: Shri Arup Kr. Sinha, CIT
Section 143(3)Section 80I

…ition 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’. (D) The Hon’ble Supreme Court in the case of Associated Cement Co. Ltd vs CIT reported in 201 ITR 435 (SC) had interpreted the term ‘work’ as below:- No ambiguity is found in the language employed in section 194C(1 ). On plain reading of said section, what is contained in the sub-section, admits of the following formulations: (1) A contract may be entered into between the contractor and any of the organisations specified in the sub-section. (2) C…

The Commissioner of Income Tax I vs. Mesmer Technologies Ltd

ITTA/673/2016HC Telangana15 Dec 2016

Bench: SANJAY KUMAR,M.S.K.JAISWAL

ITO (TDS) 2(3), Mumbai vs. Mandke Foundation, Mumbai

In the result, the appeal filed by the Revenue in ITA No

ITA 5776/MUM/2014[2011-12]Status: DisposedITAT Mumbai06 Dec 2016AY 2011-12

Bench: Shri Joginder Singh & Shri Ramit Kocharआयकर अपील सं./I.T.A. No. 5776/Mum/2014 ("नधा"रण वष" / Assessment Year : 2011-12)

For Appellant: Shri Amit Khatiwala
Section 194CSection 194JSection 201(1)

…our for carrying out work by these vendors as detailed above and hence the assessee has rightly deducted tax at source u/s 194C of the Act. Reference is drawn to decision of the Hon’ble Supreme court in the case of Associated Cement Co. Ltd. v. CIT in (1993) 201 ITR 435(SC), wherein Hon’ble Apex Court has held that there is nothing in the section which could make the Court hold that the contract to carry out a work or the contract to supply labour to carry out a work should be confined to 'works contract'. The Hon’ble Apex Court held that 'Any work' means any work and not a 'works contract', which has a special…

ITO, WD-33(4), Kolkata vs. M/S Somdatt Builders Simplex Jv, Kolkata

In the result, Revenue’s appeals are dismissed

ITA 288/KOL/2014[2007-2008]Status: DisposedITAT Kolkata07 Oct 2016AY 2007-2008

Bench: Shri Waseem Ahmed, Am & Shri K. Narasimha Chary, Jm आयकर अपील सं./Ita Nos.285, 286, 287 & 288/Kol/2014 ("नधा"रण वष" / Assessment Years :2008-09, 2009-10, 2010-11 & 2007-08) Income Tax Officer, Vs. M/S Somdatt Builders Ward-33(4), Kolkata, 10-B, Simplex Jv, 12/1, Neelie Middleton Row, 3Rd Floor, Sengupta Sarani, Kolkata- Kolkata-700071 87 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabas 9777 J .. (अपीलाथ" /Appellant) (""यथ" / Respondent)

For Appellant: Shri Ravi Tulsiyan, FCAFor Respondent: None
Section 143(3)Section 80

…in the purview of "works contract". Further, attention is invited to the judgment of the Supreme Court in case of I.T.A. Nos. 285, 286, 287 & 288/KOL./2014 Assessment years: 2008-2009 to 2010-11 & 2007-2008 Page 11 of 18 Associated Cement Co. Ltd. vs. CIT [201 ITR 435], wherein the Hon'ble Court while interpreting the term 'work' u/s 194C held that “Words `any work' in sub-s. (1) of s. 194C 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…

ITO, WD-33(4), Kolkata vs. M/S Somdatt Builders Simplex Jv, Kolkata

In the result, Revenue’s appeals are dismissed

ITA 287/KOL/2014[2010-2011]Status: DisposedITAT Kolkata07 Oct 2016AY 2010-2011

Bench: Shri Waseem Ahmed, Am & Shri K. Narasimha Chary, Jm आयकर अपील सं./Ita Nos.285, 286, 287 & 288/Kol/2014 ("नधा"रण वष" / Assessment Years :2008-09, 2009-10, 2010-11 & 2007-08) Income Tax Officer, Vs. M/S Somdatt Builders Ward-33(4), Kolkata, 10-B, Simplex Jv, 12/1, Neelie Middleton Row, 3Rd Floor, Sengupta Sarani, Kolkata- Kolkata-700071 87 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabas 9777 J .. (अपीलाथ" /Appellant) (""यथ" / Respondent)

For Appellant: Shri Ravi Tulsiyan, FCAFor Respondent: None
Section 143(3)Section 80

…in the purview of "works contract". Further, attention is invited to the judgment of the Supreme Court in case of I.T.A. Nos. 285, 286, 287 & 288/KOL./2014 Assessment years: 2008-2009 to 2010-11 & 2007-2008 Page 11 of 18 Associated Cement Co. Ltd. vs. CIT [201 ITR 435], wherein the Hon'ble Court while interpreting the term 'work' u/s 194C held that “Words `any work' in sub-s. (1) of s. 194C 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…

ITO, WD-33(4), Kolkata vs. M/S Somdatt Builders Simplex Jv, Kolkata

In the result, Revenue’s appeals are dismissed

ITA 286/KOL/2014[2009-2010]Status: DisposedITAT Kolkata07 Oct 2016AY 2009-2010

Bench: Shri Waseem Ahmed, Am & Shri K. Narasimha Chary, Jm आयकर अपील सं./Ita Nos.285, 286, 287 & 288/Kol/2014 ("नधा"रण वष" / Assessment Years :2008-09, 2009-10, 2010-11 & 2007-08) Income Tax Officer, Vs. M/S Somdatt Builders Ward-33(4), Kolkata, 10-B, Simplex Jv, 12/1, Neelie Middleton Row, 3Rd Floor, Sengupta Sarani, Kolkata- Kolkata-700071 87 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabas 9777 J .. (अपीलाथ" /Appellant) (""यथ" / Respondent)

For Appellant: Shri Ravi Tulsiyan, FCAFor Respondent: None
Section 143(3)Section 80

…in the purview of "works contract". Further, attention is invited to the judgment of the Supreme Court in case of I.T.A. Nos. 285, 286, 287 & 288/KOL./2014 Assessment years: 2008-2009 to 2010-11 & 2007-2008 Page 11 of 18 Associated Cement Co. Ltd. vs. CIT [201 ITR 435], wherein the Hon'ble Court while interpreting the term 'work' u/s 194C held that “Words `any work' in sub-s. (1) of s. 194C 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…

ITO, WD-33(4), Kolkata vs. M/S Somdatt Builders Simplex Jv, Kolkata

In the result, Revenue’s appeals are dismissed

ITA 285/KOL/2014[2008-09]Status: DisposedITAT Kolkata07 Oct 2016AY 2008-09

Bench: Shri Waseem Ahmed, Am & Shri K. Narasimha Chary, Jm आयकर अपील सं./Ita Nos.285, 286, 287 & 288/Kol/2014 ("नधा"रण वष" / Assessment Years :2008-09, 2009-10, 2010-11 & 2007-08) Income Tax Officer, Vs. M/S Somdatt Builders Ward-33(4), Kolkata, 10-B, Simplex Jv, 12/1, Neelie Middleton Row, 3Rd Floor, Sengupta Sarani, Kolkata- Kolkata-700071 87 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabas 9777 J .. (अपीलाथ" /Appellant) (""यथ" / Respondent)

For Appellant: Shri Ravi Tulsiyan, FCAFor Respondent: None
Section 143(3)Section 80

…in the purview of "works contract". Further, attention is invited to the judgment of the Supreme Court in case of I.T.A. Nos. 285, 286, 287 & 288/KOL./2014 Assessment years: 2008-2009 to 2010-11 & 2007-2008 Page 11 of 18 Associated Cement Co. Ltd. vs. CIT [201 ITR 435], wherein the Hon'ble Court while interpreting the term 'work' u/s 194C held that “Words `any work' in sub-s. (1) of s. 194C 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…

D.C.I.T CC - Xxviii, Kolkata vs. M/S Spml Infra Ltd (Erstwhile M/S Subhas Projects& Marketing Ltd), Kolkata

In the result, Revenue’s appeal is dismissed

ITA 1291/KOL/2013[2006-07]Status: DisposedITAT Kolkata24 Aug 2016AY 2006-07

Bench: Shri Waseem Ahmed & Shri S.S.Viswanethra Ravi

Section 143(3)Section 194CSection 80Section 80l

…r, procures material from a third party. Thus, contracts involving mere labour of the contractor are included in the purview of "works contract". Further, attention is invited to the judgment of the Supreme Court in case of Associated Cement Co. Ltd. vs. CIT [201 ITR 435], wherein the Hon'ble Court while interpreting the term 'work' u/s 194C held that “Words `any work' in sub-s. (1) of s. 194C 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…

Indian Oil Corporation Ltd. Marketing Division (Eastern Region), Kolkata vs. DCIT, Circle - 58 (TDS)/Kolkata, Kolkata

In the result, assessee’s appeal is allowed

ITA 1517/KOL/2009[2002-03]Status: DisposedITAT Kolkata20 Jul 2016AY 2002-03

Bench: Shri Waseem Ahmed & Shri S.S.Viswanethra Ravi

Section 133ASection 194CSection 201Section 201(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA BENCH “C” KOLKATA Before Shri Waseem Ahmed, Accountant Member and Shri S.S.Viswanethra Ravi, Judicial Member ITA No.1517-1519/Kol/2009 Assessment Years:2002-03 to 2004-05 Indian Oil Corporation DCIT, Circle-58 (TDS), बनाम Ltd. Marketing Division, Kolkata, 10B, Middleton / V/s. (Eastern Region), Indian Row, Kolkata-700 071 Oil Bhavan, 2, Gariahat Road (South), Kolkata-700 068 [PAN No.AAACI 1681 G] .. अपीलाथ" /Appellant ""यथ" /Respondent Shri Soumitra Chowdhury, Advocate आवेदक क" ओर से/By Assessee Shri Niloy Boran Som, JCIT-DR राज"व क" ओर से/By Revenue 18-05-2016 सु…