Bench: Shri Om Prakash Kantshri Pavan Kumar Gadale
44,79,11,000) (wrongly taken by A.O as Rs.47,00,00,000/-). It also provides for supply of all supervisory services at the time of erection, commissioning, integration of the plant with the existing mill. The appellant has made the payment without making TDS on the ground that the impugned contract is a contract for sale