ITO WARD-1(1) NAGPUR, NAGPUR vs. ASHWAMI SALES AND MARKETING PVT.LTD, NAGPUR
In the result, appeal filed by the Revenue is dismissed
ITA 294/NAG/2023[2013-14]Status: DisposedITAT Nagpur21 Aug 2024AY 2013-14
Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member
For Appellant: Shri Hitesh P. ShahFor Respondent: Shri Kailash C. Kanojiya
Section 143(1)Section 194(7)Section 194CSection 194C(6)Section 194C(7)Section 40Section 40A(2)(b)
…e context of section do not admit of any other interpretation. 12. Our understanding of the terms ―Contractee‖ and ―Contractor‖ is fortified by the judgement of Allahabad High Court in Moradbad Chartered Accountants vs Central Board of Direct Taxes And Anr. - 264 ITR 374 (All), wherein it is clearly held that a bare perusal of s. 194C shows that the said provision really deals with contractors who are businessmen, e.g., building contractor, or contractor who does work of transportation or loading of goods, or for supply of materials. Further it was held in Kirloskar Brothers Limited vs. DCIT (IT AT Pune)- 167 TTJ…