How many judgments cite CIT v. United Rice Land Ltd.?

19 judgments on BharatTax cite CIT v. United Rice Land Ltd. (322 ITR 594), spanning 2015 to 2025.

Which sections of the Income Tax Act does CIT v. United Rice Land Ltd. come up under?

It is most often cited in judgments turning on Section 194C, Section 40(a)(ia), Section 143(3), Section 133A(2A), Section 147, Section 194C(1).

CIT v. United Rice Land Ltd.

322 ITR 594High Court2010#6191 most cited

What is CIT v. United Rice Land Ltd. authority for?

Section 194C is attracted when payments are made for carrying out work in pursuance of a contract with a specified person. If vehicles are hired on an 'as and when needed' basis, Section 194C may not apply.

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2025.

Also referred to as

CIT v. United Rice Land Ltd. · section 194C · TDS · contract for work · labour supply · vehicle hire · as and when needed basis

Also reported as

174 Taxmann 286

Sections most often in play

Section 194C Section 40(a)(ia)Section 143(3)Section 133A(2A)Section 147 Section 194C(1)Section 194C(1)(k)Section 194C(2)

Issues it is cited on

section 194c section 40(a)(ia)section 194 section 201 section 19 section 20 income-tax officer salary prescribed person section 143(3)company

Judgments citing CIT v. United Rice Land Ltd.

ITO, TDS, RANCHI, RANCHI vs. M/S. CHHINAMASTIKA CEMENT & ISPAT PVT. LTD.,, RAMGARH

In the result, the grounds of appeal raised by the revenue are dismissed

ITA 18/RAN/2022[16-17]Status: DisposedITAT Ranchi27 May 2025

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

Section 133Section 133A

…9. We have considered the rival submissions and it is found that the Coordinate Bench of ITAT Mumbai in the case of City Transport Corporation Vs ITO 13 SOT 479 (Mum Trib) and the Hon'ble Punjab & Haryana High Court in the case of CIT Vs United Rice Land Ltd. 322 ITR 594 (P&H) have already held that as ITO Vs M/s Maa Chhinamastika Cement & Ispat (P) Ltd. per provisions of Section 194C of the Act, any person responsible for paying any sum to any resident for carrying out any work in pursuance of a contract shall at the time of credit of such sum or at the time of payment thereof in cash or by cheque deduct a tax t…

ITO, TDS,, RANCHI vs. M/S. CHINNAMASTIKA CEMENT & ISPAT LTD.,, RAMGARH

In the result, the grounds of appeal raised by the revenue are dismissed

ITA 17/RAN/2022[15-16]Status: DisposedITAT Ranchi27 May 2025

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

Section 133Section 133A

ASHOKKUMAR PROJECTS INDIA PVT. LTD.,PORBANDAR vs. THE PR. CIT, JAMNAGAR, JAMNAGAR

In the result, appear of the assessee is allowed

ITA 83/RJT/2024[2018-19]Status: DisposedITAT Rajkot21 Mar 2025AY 2018-19

Bench: Dr.Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.83/Rjt/2024 (िनधा"रणवष" / Assessment Year: (2018-19) (Physical Hearing) Ashokkumar Projects India P. Vs. The Pr. Commissioner Of Ltd. Income Tax, 4Th Floor, Manek Centre, P.N. Cholera Arcade, M.G. Road Opposite, Bhaveshwar Mahadev Marg, Jamnagar - 361008 Temple, Porbandar – 360575 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aamca5891Q (Assessee) (Respondent)

For Appellant: Shri Dushyant Maharshi, ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)

Section 142(1)Section 143(3)Section 192Section 194CSection 263Section 40

…mi Protein Products (P) Ltd. [2010] 195 Taxman 32 (Ahd.) (2)CIT v. Mrinalini Biri Mfgg. Co. Ltd. [1992] 105 CTR 327 (Kol.) (3)Samanwaya v. Asstt. CIT [2009] 34 SOT 332 (Kol.) (4)CIT v. Bhagwati Steels [2010] 326 ITR 108. (5)CIT v. United Rice Land Ltd. [2010] 322 ITR 594. The ld. Counsel also submitted that that mere non-compliance of PF/ESI Act does not result in a change in nature of the payment made to Casual workers, as contractual payment, so as to attract TDS u/s. 194C of the Act. Section 194C of the Act is attracted when any payment is made for carrying out any work (including supply of labour for carrying…

PARTHO DAS,MUMBAI vs. INCOME TAX OFFICER-28(2)(4), MUMBAI, NAVI MUMBAI

In the result, appeal of the assessee is allowed

ITA 5379/MUM/2024[2006-07]Status: DisposedITAT Mumbai18 Dec 2024AY 2006-07

Section 143(3)Section 194CSection 194C(1)Section 194C(1)(K)Section 194C(1)(k)Section 194C(2)Section 40Section 44A

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘C’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA No.5379/Mum/2024 (Assessment Year :2006-07) Shri Partho Das Vs. Income Tax Officer- Marine Center 28(2)(4), Mumbai Marine Street, Sector-11 Vashi, Mumbai-400 703 PAN/GIR No.AAMPD7473J (Appellant) (Respondent) Assessee by Shri Rakesh Joshi Revenue by Shri Krishna Kumar Date of Hearing 26/11/2024 Date of Pronouncement 18/12/2024 आदेश / ORDER PER AMIT SHUKLA (J.M): The aforesaid appeal has been filed by the assessee against order dated 16/08/2024 passed by NFAC, Delhi for the…

MEASAGE.TAU AGRO SALES PRIVATE LIMITED,FARIDKOT vs. INCOME TAX OFFICER WARD-3(4), FARIDKOT

In the result the ground no

ITA 325/ASR/2019[2015-16]Status: DisposedITAT Amritsar22 Sept 2022AY 2015-16

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 250Section 36Section 36(1)(iii)Section 40A(3)

…rtation of goods for a specific period, quantity or price. The aforesaid fact being an essential feature to test the applicability of section 194C of the Act as considered by Division Bench of this Court in the case of CIT (TDS) v. United Rice Land Ltd.[2010] 322 ITR 594 1. A further finding of fact is that the freight payment is Rs. 1,72,723 and none of the individual payment exceeded Rs. 20,000. It was also not disputed that the payments were made on the basis of individual GRs issued by the truck owners for each trip separately. Although aggregate of payments of two truck owners during the assessment year exce…

MEASAGE TAU AGRO SALES PRIVATE LIMITED,FARIDKOT vs. INCOME TAX OFFICER WARD-3(2), FEROZEPUR

In the result the ground no

ITA 324/ASR/2019[2014-15]Status: DisposedITAT Amritsar22 Sept 2022AY 2014-15

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 250Section 36Section 36(1)(iii)Section 40A(3)

M/S. BALASORE CO-OPERATIVE URBAN BANK LTD.,BALASORE vs. ACIT, BALASORE CIRCLE, BALASORE

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 467/CTK/2017[2012-13]Status: DisposedITAT Cuttack07 Oct 2020AY 2012-13

Bench: Shri C.M. Garg, Jm & Shri L.P. Sahu, Am आयकर अऩीऱ सं./Ita No.467/Ctk/2017 (नििाारण वषा / Assessment Year :2012-2013) M/S Balasore Cooperative Bank Vs. Acit, Balasore Circle, Limited, Balasore Bibekananda Marg, Balasore-756001 Pan No. : Aaccb 7823 M (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri S.N.Sahu/Somnath Sahoo,Advs राजस्व की ओर से /Revenue By : Shri M.K.Gautam, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 13/08/2020 घोषणा की तारीख/Date Of Pronouncement : 12/10/2020 आदेश / O R D E R Per L.P.Sahu, Am: This Is An Appeal Filed By The Assessee Against The Order Passed By The Cit(A), Cuttack, Dated 04.08.2017, For The Assessment Year 2012-2013, On The Following Grounds Of Appeal :- 1) That The Order Of The Id. Cit(Appeals) Confirming The Additions & Disallowances Made By The A.O. Is Illegal, Arbitrary, Unjustified & Not In Accordance With Law. 2) That The Addition Of Rs. 36,79,148/- U/S. 40(A)(Ia) Of The I.T. Act, 1961 Confirmed By Cit(Appeals) To The Extent Of Rs. 36,30,998/- Is Illegal, Arbitrary, Uncalled For & Not In Accordance With Law & The Same Should Have Been Deleted By The Learned Cit(Appeals). 3) That The Disallowance U/S 40(A)(Ia) Of Rs. 36,79,148/- As Detailed Below Is Illegal, Arbitrary & Unjustified & Hence Should Have Been Deleted By The Learned Cit(A) As The Genuineness Is Not In Doubt. Non-Deduction Of Tds Is A Separate Issue. A) Commission Payment To Dlds Collection Agents Rs. 33,45,248/- B) Legal Expenses Rs. 2,52,000/- C) Audit Fees Rs. 81,900/-

For Appellant: Shri S.N.Sahu/Somnath Sahoo,AdvsFor Respondent: Shri M.K.Gautam, CIT-DR

Section 36Section 40Section 43B

…period, quantity or price. Nothing has been brought on record by the AO to prove that the persons paid were in pursuance of a contract. Therefore, Section 40(a)(ia) has no application has been decided in the case of CIT Vs. United Rice Land Ltd, 217 CTR 332, 322 ITR 594 (P&H), (Page No. 71 of the Paper Book). The Honourable I.T.A.T., Cuttack Bench following the 8 above case law has deleted additions in a plethora of decisions. A few of them are given below. i) R.R. Carrying Corporation Vs. ACIT, 126 TTJ 240 (Ctk) ii) Chandrakant Thacker Vs. ACIT, 129 TTJ 1 (Ctk) iii) Sanjay Kumar Pradhan Vs. ACIT, 14 ITR (Trib)…

SHRI ANIL KHANDELWAL,INDORE vs. THE ITO-5(3), INDORE

In the result the appeal of the assessee is allowed

ITA 299/IND/2016[2009-10]Status: DisposedITAT Indore12 Oct 2018AY 2009-10

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2009-10

Section 143(3)Section 194(3)Section 194CSection 194C(3)Section 263Section 40

…Anil Khandelwal आयकर अपील"य अ"धकरण, इंदौर "यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL, INDORE BENCH, INDORE BEFORE SHRI KUL BHARAT, JUDICIAL MEMBER AND SHRI MANISH BORAD, ACCOUNTANT MEMBER Assessment Year: 2009-10 Shri Anil Khandelwal, ITO 5(3), 113, Sudarshan Complex, Vs. Indore Bhavarkuan Main Road, Indore (Appellant) (Respondent ) PAN No.ACBPK8401C Revenue by Shri P.K. Mitra, Sr.DR Assessee by Shri Thribhuvan Sachdeva,C.A Date of Hearing 05.10.2018 Date of Pronouncement 12.10.2018 O R D E R PER MANISH BORAD, AM. This appeal of Assessee pertaining to A.Y. 2009-10 is directed against the order of Ld…

NAYEEM NOOR KHAN MOMIN,MUMBAI vs. CIT 21, MUMBAI

In the result, assessee’s appeal is allowed

ITA 6259/MUM/2014[2009-10]Status: DisposedITAT Mumbai07 Feb 2018AY 2009-10

Bench: Shri D.T. Garasia & Shri N.K. Pradhanassessment Year: 2009-10

For Appellant: Shri Dinkle Haria, A.RFor Respondent: Shri Rahul Raman, D.R

Section 143(3)Section 194Section 263Section 40

…t the payment in respect of hiring vehicles wherein consequences of any written or oral agreement before provisions of section 194-I would be invoked. 5. Keeping in mind the principles laid down in many cases like in the case of CIT vs. United Rice Land Ltd. 322 ITR 594 (P&H) wherein it was held that wherever the trucks were taken on hire by the assessee on as and when basis it was held that section 194(c) would not be applicable. We find that assessee’s plea is that assessee hires the vehicles from various persons. We find that assessee has hired vehicles from 56 persons which reads as under: 5 Mr. Nayeem Noor…

SAMANAWAYA,HOOGHLY vs. ACIT, CIR-2, BWN, BURDWAN

In the result, the appeal of the assessee is allowed

ITA 633/KOL/2014[2007-2008]Status: DisposedITAT Kolkata31 Oct 2017AY 2007-2008

Bench: Hon’Ble Shri J.Sudhakar Reddy, Am & Shri S.S.Viswanethra Ravi, Jm] Assessment Year : 2007-08

For Appellant: Shri Somnath Ghosh, AdvocateFor Respondent: Shri Sallong Yaden, Addl. CIT

Section 143(3)Section 194CSection 194C(1)Section 251Section 40

…of section 194C(1) of the Act are not applicable. The payments were made directly to truck drivers on delivery of goods. The issue stands covered in favour of the assessee by the decision of the Hon’ble Punjab and Haryana High Court in the case of CIT vs Unit 322 ITR 594 (P&H) and the decision of the Hon’ble Gujarat High Court in the case of CIT vs Prashant H.Shah (2013) 216 Taxman 287 (Guj.). As there is no written contract in this case between the assessee and the lorry owners, the ITA No.633/Kol/2014-Samanawaya A.Y.2007-08 3 conclusion of the ld. CIT(A) that there was violation of section 194C of the Act cons…

ANIL KUMAR PAIK,KOLKATA vs. J.C.I.T (OSD) UNDER CIT - III, KOL, KOLKATA

In the result, the appeal of the assessee is dismissed

ITA 2297/KOL/2013[2009-10]Status: DisposedITAT Kolkata21 Jun 2017AY 2009-10

Bench: Shri P.M. Jagtap & Shri A.T. Varkey

Section 143(3)Section 44A

…I.T.A. No. 2297/KOL./2013 Assessment year: 2009-2010 Page 1 of 13 IN THE INCOME TAX APPELLATE TRIBUNAL, KOLKATA ‘A’ BENCH, KOLKATA Before Shri P.M. Jagtap, Accountant Member and Shri A.T. Varkey, Judicial Member I.T.A. No. 2297/KOL/ 2013 Assessment Year: 2009-2010 Anil Kumar Paik,............................................................................Appellant Flat 2ABC, 2B, S.N. Roy Road, Behala, Kolkata-700 034 [PAN: AFLPP 6567 R] -Vs.- Joint Commissioner of Income Tax (OSD),...................................Respondent C.I.T.-III, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700 069 Appearances by:…

BAIJNATH MELARAM,MUMBAI vs. ADDL CIT RG 14(3), MUMBAI

In the result, these appeals filed by the assessee are partly allowed

ITA 598/MUM/2012[2007-08]Status: DisposedITAT Mumbai27 Jan 2017AY 2007-08

Bench: Shri Joginder Singh & Shri Ashwani Tanejaassessment Year: 2007-08 & Assessment Year: 2008-09 Baijnath Melaram, Acit Rg 14(3) C/O. Mangaldas D Shah & Co. बनाम/ 6Th Floor, Earnest 506, Lotus House, 5Th Floor, House, Vs. 33-A, New Marine Lines, Mumbai-400021 Mumbai-400020 (Appellant) (Respondent ) P.A. No.Aaafb2675E Appellant By Shri Dhirendra M. Shah (Ar) Revenue By Shri Suman Kumar (Dr) सुनवाई की तारीख/Date 21/12/2016 Of Hearing: आदेश की तारीख /Date Of Order: 27/01/2017 आदेश / O R D E R Per Ashwani Taneja: These Appeals Pertain To Same Assessee For The Two Different Years Involving Identical Issues, Therefore, These Were Heard Together & Being Disposed By This Common Order: 2. First We Shall Take Appeal For A.Y. 2007-08 Filed By The Assessee Against The Order Of Ld. Cit(A) Dated 24.10.2011 Passed Against The Assessment Order Of The Ao U/S 143(3)

Section 143(3)Section 36

…portation of goods. Thus, in absence of any written or oral agreement, provisions of section 194C were not applicable. Reliance was placed in this regard on the judgment of Hon’ble Punjab and Haryana High Court in the case of CIT. vs. United Rice Land Limited 322 ITR 594 (P& H) and Amritsar Bench of the 15 Baijnath Melaram Tribunal in the case of DCIT vs. Satish Aggarwal & Co. 317 ITR (AT) 196 (Amritsar). It was also submitted that none of the amounts remained payable at the close of the concerned financial year, therefore, provisions of section 40(a)(ia) could not have been invoked in absence any amount remainin…

BAIJNATH MELARAM,MUMBAI vs. ADDL CIT RG 14(3), MUMBAI

In the result, these appeals filed by the assessee are partly allowed

ITA 597/MUM/2012[2008-09]Status: DisposedITAT Mumbai27 Jan 2017AY 2008-09

Section 143(3)Section 36

M/S GOA BAMBAY ROADLINES vs. CIT, HISAR

In the result, the appeal of the assessee stands allowed

ITA 3104/DEL/2013[2008-09]Status: DisposedITAT Delhi29 Aug 2016AY 2008-09

Bench: Shri S.V. Mehrotra & Shri Chandra Mohan Garg

For Appellant: Shri Gurjeet Singh & Rakesh Jain, AdvsFor Respondent: Shri A.K. Saroha, CIT-DR

Section 143(3)Section 194C(3)(i)Section 194C(6)Section 263Section 263(1)Section 40

…R has placed reliance on the decision of the Hon'ble High Court in the case of CIT Vs. Sunbeam Auto Ltd reported at [2011] 332 ITR 167 [DHC] and the decision of the Hon'ble Punjab and Haryana High Court in the case of United Role Land Ltd reported at [2010] 322 ITR 594 [P&H]. The ld. AR also drew our attention towards the judgment of the Hon'ble 8 Supreme Court in the case of CIT Vs. Max India Ltd [2007] 295 ITR 282 [SC] and submitted that the CIT passed impugned order u/s 263 of the Act and it was held by the Hon'ble High Court that where two view are possible and the ITO has taken one view with which the C…

ITO, WARD - 1(3), BURDWAN, BURDWAN vs. M/S. DAGA TRANSPORT AGENCY, BURDWAN

In the result, both the appeals of the revenue are allowed for statistical purposes

ITA 2295/KOL/2010[2004-05]Status: DisposedITAT Kolkata03 Aug 2016AY 2004-05

Bench: Shri M. Balaganesh, Am & Shri K. Narasimha Chary, Jm]

For Appellant: Shri Niraj Kumar, CIT, DR &For Respondent: N o n e

Section 133(6)Section 147Section 263Section 271(1)(c)

…1 ITA Nos. 2295-2296/Kol/2010 Daga Transport Agency, AY 2004-05 & 2005-06 IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH: KOLKATA [Before Shri M. Balaganesh, AM & Shri K. Narasimha Chary, JM] I.T.A Nos. 2295 & 2296/Kol/2010 Assessment Years: 2004-05 & 2005-06 Income-tax Officer, Wd-1(3), Burdwan. Vs. M/s. Daga Transport Agency (PAN: AADED6287F) (Appellant) (Respondent) Date of hearing: 01.08.2016 Date of pronouncement: 03.08.2016 For the Appellant: Shri Niraj Kumar, CIT, DR & Shri Debasish Banerjee, JCIT, Sr. DR For the Respondent: N o n e ORDER Per Shri K. Narasimha Chary, JM: Both these appeals by reve…

I.T.O WD - 34(2),KOLKATA., KOLKATA vs. M/S AKSHOY KUMAR GHOSE & SONS., KOLKATA

In the result, the appeal of the Revenue is treated as allowed as indicated above

ITA 156/KOL/2013[2009-10]Status: DisposedITAT Kolkata16 Dec 2015AY 2009-10

Bench: Shri P.M. Jagtap & Shri S.S. Viswanethra Ravi

Section 194CSection 40

…I.T.A. No. 156/KOL./2013 Assessment year: 2009-2010 Page 1 of 6 IN THE INCOME TAX APPELLATE TRIBUNAL, KOLKATA ‘C’ BENCH, KOLKATA Before Shri P.M. Jagtap, Accountant Member and Shri S.S. Viswanethra Ravi, Judicial Member I.T.A. No. 156/KOL/ 2013 Assessment Year : 2009-2010 Income Tax Officer,.................................................................Appellant Ward-34(2), Kolkata, Aayakar Bhawan (Poorva), 110, Shantipally (7th Floor), Kolkata-700 107 -Vs.- M/s. Akshoy Kumar Ghose & Sons,.........................................Respondent 15/1, Strand Road, Customs House Kolkata-700 001 [PAN : AAIFA 2121 L]…

ITO 24(3)(1), MUMBAI vs. GOPAL S. RAJPUT, MUMBAI

In the result, the appeal filed by the Revenue is allowed

ITA 1687/MUM/2011[2007-08]Status: DisposedITAT Mumbai30 Nov 2015AY 2007-08

Bench: Shri Amit Shukla & Shri Ramit Kocharआयकर अपील सं./I.T.A. No. 1687/Mum/2011 ("नधा"रण वष" / Assessment Year : 2007-08)

For Appellant: None

Section 143(2)Section 143(3)Section 194CSection 40

…e meaning of section 194C of the Act. To this effect, the assessee relied on the judgment of Hon’ble Punjab & Haryana High Court in the case of CIT (TDS) vs. M/s United Rice Land Limited in ITA No. 633 of 2007 dated 12-05-2008 which is also reported in (2008) 174 Taxmann 286 (P&H HC). The assessee also filed written submissions vide averments in the form of Affidavit, which are as under:- ITA 1687/M/11 4 “I Gopalji S. Rajput (Prop. Of M/s Express Transport) aged about 48 years, Indian Inhabitant of Goregaon Dist. Mumbai 400 062 presently residing at 18, Jiya Welfare Society, S.V. Road, Goregaon (West), Dost. M…

ITO, WARD-45(2), KOLKATA, KOLKATA vs. M/S ASHOK TRADING COMPANY, KOLKATA

In the result, Revenue’s appeal is partly allowed for statistical purpose

ITA 650/KOL/2012[2006-07]Status: DisposedITAT Kolkata07 Oct 2015AY 2006-07

Bench: Shrin.V.Vasudevan & Shri Waseem Ahmedassessment Year :2006-07

Section 143(3)(II)Section 194CSection 40Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA BENCH “B” KOLKATA Before ShriN.V.Vasudevan, Judicial Member and Shri Waseem Ahmed, Accountant Member Assessment Year :2006-07 I.T.O. Ward-45(2), 3, V/s. M/s Ashok Trading Govt. Place (W), Gr. Company, 13, Floor, Kolkata – 01 NoormalLohia Lane, Kolkata-07 [PAN No.AAGFA 0299 M] .. अपीलाथ" /Appellant ""यथ"/Respondent ShriPinaki Mukherjee, JCIT-SR-DR अपीलाथ" क" ओर से/By Appellant Shri V.N. Purohit, FCA ""यथ" क" ओर से/By Respondent 09-09-2015 सुनवाई क" तार"ख/Date of Hearing 07-10-2015 घोषणा क" तार"ख/Date of Pronouncement आदेश/O R D E R PER Waseem Ahmed, AccountantMem…

THE COMMISSIONER OF INCOME TAX vs. M/S MARUTI SUBRAY PATIL

The appeal stands disposed of in the above terms

ITA/5027/2010HC Karnataka29 Jul 2015

Bench: The Hon’Ble Mr.Justice Ravi Malimath & The Hon’Ble Mr.Justice G. Narendar

Section 194CSection 194C(2)Section 260Section 260ASection 40

…railways. 26. The finding that the appeal requires to be allowed in view of the decision by the Co-ordinate Bench and that of the Punjab and Haryana : 23 : High Court in the case of Commissioner of Income Tax Vs. United Rice Land Limited reported in (2010) 322 ITR 594 (P&H) is erroneous. Therein the finding of fact, that the amounts paid to the transporter is by way of hire charges, was rendered on the basis of evidence furnished by the alleged transporters. The assessee therein was in the manufacturer and export of rice and there was an identified route, quantity etc., in view of which certain facts could be…