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23 results for “TDS”+ Section 194C(3)clear

Sorted by relevance

Mumbai699Delhi649Kolkata436Bangalore297Chennai190Jaipur85Ahmedabad70Hyderabad60Indore51Karnataka50Raipur38Rajkot29Pune26Cochin25Nagpur23Amritsar23Jodhpur22Chandigarh20Patna19Surat16Guwahati12Cuttack12Visakhapatnam11Panaji11Lucknow9Ranchi9Kerala8Jabalpur8Allahabad8Telangana7Calcutta6Agra5SC5Dehradun4Rajasthan2Gauhati1Orissa1A.K. SIKRI ROHINTON FALI NARIMAN1

Key Topics

Section 194C45Section 143(3)21Section 80I18Deduction17Section 4016Section 201(1)16TDS15Disallowance13Section 14712Section 153A

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)

Section 194C(7) have to be read together to extend the immunity from TDS, our attention is drawn to the fact that though the Finance Act, (N0.2) 2009 introduced, inter alia, Sec. 194C(6) and 194C(7), similar and analogous provision had been very much in existence under proviso 2 and 3

Showing 1–20 of 23 · Page 1 of 2

12
Addition to Income11
Section 143(1)9

ITO (TDS), WARD-2(3),, CHANDRAPUR vs. ACC LTD.,, CHANDRAPUR

In the result, the appeal filed by the Revenue in ITA

ITA 73/NAG/2017[2011-12]Status: DisposedITAT Nagpur31 Jul 2023AY 2011-12

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / Ita Nos.73 To 76/Nag/2017 िनधा"रण वष" / Assessment Years : 2011-12 To 2014-15 Ito (Tds), Ward-2(3), Vs. Acc Ltd., Chandrapur- 442401. Chanda Cement Works, P.O. Cement Nagar, Chandrapur, Dist.- Chandrapur, Chandrapur - 442502. Pan : Aaact1507C Appellant Respondent Revenue By : Shri Maurya Pratap Assessee By : Shri Chaitanya D. Joshi Date Of Hearing : 20.07.2023 Date Of Pronouncement : 31.07.2023 आदेश / Order Per Inturi Rama Rao, Am: These Are The Appeals Filed By The Revenue Directed Against The Common Order Of Ld. Commissioner Of Income Tax (Appeals)-2, Nagpur [‘The Cit(A)’] Dated 26.12.2016 Quashing The Order Passed By The Income Tax Officer (Tds), Ward-2(3), Chandrapur U/S 201(1) Of The Income Tax Act, 1961 (‘The Act’) For The Assessment Years 2011-12 To 2014-15 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In The Above Captioned Four Appeals Of The Revenue, We Proceed To Dispose Of The Same By This Common Order. 3. For The Sake Of Convenience & Clarity, The Facts Relevant To The Appeal Of The Revenue In Ita No.73/Nag/2017 For The Assessment Year 2011-12 Are Stated Herein.

For Appellant: Shri Chaitanya D. JoshiFor Respondent: Shri Maurya Pratap
Section 133ASection 194CSection 201(1)

TDS Officer misconstrued the provisions of sub-section (6) of section 194C, which is not the requirements of law that the assessee should carriages. However, the ld. CIT(A) merely made a reference to the submissions of the assessee that it had complied with the provisions of sub-section (6) of section 194C of the Act read with Rule

ITO (TDS), WARD-2(3),, CHANDRAPUR vs. ACC LTD.,, CHANDRAPUR

In the result, the appeal filed by the Revenue in ITA

ITA 74/NAG/2017[2012-13]Status: DisposedITAT Nagpur31 Jul 2023AY 2012-13

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / Ita Nos.73 To 76/Nag/2017 िनधा"रण वष" / Assessment Years : 2011-12 To 2014-15 Ito (Tds), Ward-2(3), Vs. Acc Ltd., Chandrapur- 442401. Chanda Cement Works, P.O. Cement Nagar, Chandrapur, Dist.- Chandrapur, Chandrapur - 442502. Pan : Aaact1507C Appellant Respondent Revenue By : Shri Maurya Pratap Assessee By : Shri Chaitanya D. Joshi Date Of Hearing : 20.07.2023 Date Of Pronouncement : 31.07.2023 आदेश / Order Per Inturi Rama Rao, Am: These Are The Appeals Filed By The Revenue Directed Against The Common Order Of Ld. Commissioner Of Income Tax (Appeals)-2, Nagpur [‘The Cit(A)’] Dated 26.12.2016 Quashing The Order Passed By The Income Tax Officer (Tds), Ward-2(3), Chandrapur U/S 201(1) Of The Income Tax Act, 1961 (‘The Act’) For The Assessment Years 2011-12 To 2014-15 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In The Above Captioned Four Appeals Of The Revenue, We Proceed To Dispose Of The Same By This Common Order. 3. For The Sake Of Convenience & Clarity, The Facts Relevant To The Appeal Of The Revenue In Ita No.73/Nag/2017 For The Assessment Year 2011-12 Are Stated Herein.

For Appellant: Shri Chaitanya D. JoshiFor Respondent: Shri Maurya Pratap
Section 133ASection 194CSection 201(1)

TDS Officer misconstrued the provisions of sub-section (6) of section 194C, which is not the requirements of law that the assessee should carriages. However, the ld. CIT(A) merely made a reference to the submissions of the assessee that it had complied with the provisions of sub-section (6) of section 194C of the Act read with Rule

ITO (TDS), WARD-2(3),, CHANDRAPUR vs. ACC LTD.,, CHANDRAPUR

In the result, the appeal filed by the Revenue in ITA

ITA 75/NAG/2017[2013-14]Status: DisposedITAT Nagpur31 Jul 2023AY 2013-14

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / Ita Nos.73 To 76/Nag/2017 िनधा"रण वष" / Assessment Years : 2011-12 To 2014-15 Ito (Tds), Ward-2(3), Vs. Acc Ltd., Chandrapur- 442401. Chanda Cement Works, P.O. Cement Nagar, Chandrapur, Dist.- Chandrapur, Chandrapur - 442502. Pan : Aaact1507C Appellant Respondent Revenue By : Shri Maurya Pratap Assessee By : Shri Chaitanya D. Joshi Date Of Hearing : 20.07.2023 Date Of Pronouncement : 31.07.2023 आदेश / Order Per Inturi Rama Rao, Am: These Are The Appeals Filed By The Revenue Directed Against The Common Order Of Ld. Commissioner Of Income Tax (Appeals)-2, Nagpur [‘The Cit(A)’] Dated 26.12.2016 Quashing The Order Passed By The Income Tax Officer (Tds), Ward-2(3), Chandrapur U/S 201(1) Of The Income Tax Act, 1961 (‘The Act’) For The Assessment Years 2011-12 To 2014-15 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In The Above Captioned Four Appeals Of The Revenue, We Proceed To Dispose Of The Same By This Common Order. 3. For The Sake Of Convenience & Clarity, The Facts Relevant To The Appeal Of The Revenue In Ita No.73/Nag/2017 For The Assessment Year 2011-12 Are Stated Herein.

For Appellant: Shri Chaitanya D. JoshiFor Respondent: Shri Maurya Pratap
Section 133ASection 194CSection 201(1)

TDS Officer misconstrued the provisions of sub-section (6) of section 194C, which is not the requirements of law that the assessee should carriages. However, the ld. CIT(A) merely made a reference to the submissions of the assessee that it had complied with the provisions of sub-section (6) of section 194C of the Act read with Rule

ITO (TDS), WARD-2(3),, NAGPUR vs. ACC LTD.,, CHANDRAPUR

In the result, the appeal filed by the Revenue in ITA

ITA 76/NAG/2017[2014-115]Status: DisposedITAT Nagpur31 Jul 2023AY 2014-115

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / Ita Nos.73 To 76/Nag/2017 िनधा"रण वष" / Assessment Years : 2011-12 To 2014-15 Ito (Tds), Ward-2(3), Vs. Acc Ltd., Chandrapur- 442401. Chanda Cement Works, P.O. Cement Nagar, Chandrapur, Dist.- Chandrapur, Chandrapur - 442502. Pan : Aaact1507C Appellant Respondent Revenue By : Shri Maurya Pratap Assessee By : Shri Chaitanya D. Joshi Date Of Hearing : 20.07.2023 Date Of Pronouncement : 31.07.2023 आदेश / Order Per Inturi Rama Rao, Am: These Are The Appeals Filed By The Revenue Directed Against The Common Order Of Ld. Commissioner Of Income Tax (Appeals)-2, Nagpur [‘The Cit(A)’] Dated 26.12.2016 Quashing The Order Passed By The Income Tax Officer (Tds), Ward-2(3), Chandrapur U/S 201(1) Of The Income Tax Act, 1961 (‘The Act’) For The Assessment Years 2011-12 To 2014-15 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In The Above Captioned Four Appeals Of The Revenue, We Proceed To Dispose Of The Same By This Common Order. 3. For The Sake Of Convenience & Clarity, The Facts Relevant To The Appeal Of The Revenue In Ita No.73/Nag/2017 For The Assessment Year 2011-12 Are Stated Herein.

For Appellant: Shri Chaitanya D. JoshiFor Respondent: Shri Maurya Pratap
Section 133ASection 194CSection 201(1)

TDS Officer misconstrued the provisions of sub-section (6) of section 194C, which is not the requirements of law that the assessee should carriages. However, the ld. CIT(A) merely made a reference to the submissions of the assessee that it had complied with the provisions of sub-section (6) of section 194C of the Act read with Rule

M/S ATASHA ASHIRWAD BUILDERS,NAGPUR vs. A.C.I.T (TDS) RANGE 1, NAGPUR

In the result, the appeal of assessee is allowed

ITA 480/NAG/2016[2009-10]Status: DisposedITAT Nagpur03 Aug 2023AY 2009-10

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

For Appellant: Shri Kapil HiraniFor Respondent: Shri Amol Khairnar
Section 194CSection 200(3)Section 206C(3)Section 272A(2)(k)

194C, 194I, 194J, 194H of the Act and also has an obligation to furnish quarterly statements of TDS in Form No. 26Q within the prescribed due dates. The said details by way of a tabular form is reflected in para 2 of the order of Addl. CIT. We note that the Addl. CIT imposed penalty u/s. 272A

DY. C.I.T. CENTRAL CIR.-2(2), NAGPUR vs. SMT. ANJU SARAF, NAGPUR

In the result, all the appeals of the revenue, cross objections of the assessee are dismissed and appeals filed by the assessee are allowed

ITA 436/NAG/2016[2005-06]Status: DisposedITAT Nagpur25 Jul 2022AY 2005-06

Bench: Shrisandeepgosain & Shriarunkhodpia

For Appellant: Shri Sudesh BanthiaFor Respondent: Shri Piyush Kolhe
Section 143(3)Section 147Section 153ASection 80I

3,41,27,8737- 28 Smt. AanjuSaraf claimed and on balance tax was not deducted, since no tax is required to be deducted thereon u/s 194C. TDS has been deducted on cash payments also. The AO has failed to bring on record any infirmity or discrepancy in the vouchers/bills or any record in relation to the claim of such expenditure

DY. C.I.T. CENTRAL CIR.-2(2), NAGPUR vs. SMT. ANJU A. SARAF, NAGPUR

In the result, all the appeals of the revenue, cross objections of the assessee are dismissed and appeals filed by the assessee are allowed

ITA 512/NAG/2016[2009-10]Status: DisposedITAT Nagpur25 Jul 2022AY 2009-10

Bench: Shrisandeepgosain & Shriarunkhodpia

For Appellant: Shri Sudesh BanthiaFor Respondent: Shri Piyush Kolhe
Section 143(3)Section 147Section 153ASection 80I

3,41,27,8737- 28 Smt. AanjuSaraf claimed and on balance tax was not deducted, since no tax is required to be deducted thereon u/s 194C. TDS has been deducted on cash payments also. The AO has failed to bring on record any infirmity or discrepancy in the vouchers/bills or any record in relation to the claim of such expenditure

DY. C.I.T. CENTRAL CIR.-2(2), NAGPUR vs. SMT. ANJU A. SARAF, NAGPUR

In the result, all the appeals of the revenue, cross objections of the assessee are dismissed and appeals filed by the assessee are allowed

ITA 511/NAG/2016[2008-09]Status: DisposedITAT Nagpur25 Jul 2022AY 2008-09

Bench: Shrisandeepgosain & Shriarunkhodpia

For Appellant: Shri Sudesh BanthiaFor Respondent: Shri Piyush Kolhe
Section 143(3)Section 147Section 153ASection 80I

3,41,27,8737- 28 Smt. AanjuSaraf claimed and on balance tax was not deducted, since no tax is required to be deducted thereon u/s 194C. TDS has been deducted on cash payments also. The AO has failed to bring on record any infirmity or discrepancy in the vouchers/bills or any record in relation to the claim of such expenditure

SMT. ANJU SARAF,,NAGPUR vs. A,C.I.T CENT CIR. 2(2), NAGPUR

In the result, all the appeals of the revenue, cross objections of the assessee are dismissed and appeals filed by the assessee are allowed

ITA 499/NAG/2016[2009-10]Status: DisposedITAT Nagpur25 Jul 2022AY 2009-10

Bench: Shrisandeepgosain & Shriarunkhodpia

For Appellant: Shri Sudesh BanthiaFor Respondent: Shri Piyush Kolhe
Section 143(3)Section 147Section 153ASection 80I

3,41,27,8737- 28 Smt. AanjuSaraf claimed and on balance tax was not deducted, since no tax is required to be deducted thereon u/s 194C. TDS has been deducted on cash payments also. The AO has failed to bring on record any infirmity or discrepancy in the vouchers/bills or any record in relation to the claim of such expenditure

SMT. ANJU SARAF,,NAGPUR vs. A,C.I.T CENT CIR. 2(2), NAGPUR

In the result, all the appeals of the revenue, cross objections of the assessee are dismissed and appeals filed by the assessee are allowed

ITA 498/NAG/2016[2007-08]Status: DisposedITAT Nagpur25 Jul 2022AY 2007-08

Bench: Shrisandeepgosain & Shriarunkhodpia

For Appellant: Shri Sudesh BanthiaFor Respondent: Shri Piyush Kolhe
Section 143(3)Section 147Section 153ASection 80I

3,41,27,8737- 28 Smt. AanjuSaraf claimed and on balance tax was not deducted, since no tax is required to be deducted thereon u/s 194C. TDS has been deducted on cash payments also. The AO has failed to bring on record any infirmity or discrepancy in the vouchers/bills or any record in relation to the claim of such expenditure

DY. C.I.T. CENTRAL CIR.-2(2), NAGPUR vs. SMT. ANJU SARAF, NAGPUR

In the result, all the appeals of the revenue, cross objections of the assessee are dismissed and appeals filed by the assessee are allowed

ITA 438/NAG/2016[2010-11]Status: DisposedITAT Nagpur25 Jul 2022AY 2010-11

Bench: Shrisandeepgosain & Shriarunkhodpia

For Appellant: Shri Sudesh BanthiaFor Respondent: Shri Piyush Kolhe
Section 143(3)Section 147Section 153ASection 80I

3,41,27,8737- 28 Smt. AanjuSaraf claimed and on balance tax was not deducted, since no tax is required to be deducted thereon u/s 194C. TDS has been deducted on cash payments also. The AO has failed to bring on record any infirmity or discrepancy in the vouchers/bills or any record in relation to the claim of such expenditure

SANJAY KISAN CHOPDE,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, NAGPUR

In the result, appeal of the assessee is allowed

ITA 176/NAG/2022[2014-15]Status: DisposedITAT Nagpur30 Jan 2024AY 2014-15

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.176/Nag/2022 िनधा"रण वष" / Assessment Year : 2014-15 Sanjay Kisan Chopde, The Deputy Balaji Associates, Gs 37, Vs Commissioner Of Amar Jyoti Palace, Lomat Income Tax, Circle-1, Square, Wardha Road, Nagpur. Nagpur – 440012. Pan: Abapc6968N Appellant/ Assessee Respondent/Revenue Assessee By Shri Abhay Agrawal – Advocate Revenue By Shri Abhay Y. Marathe – Sr.Dr Date Of Hearing 25/01/2024 Date Of Pronouncement 30/01/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Dated 30.3.2022 Emanating From Assessment Order Under Section 143(3) Dated 30.06.2016 For A.Y.2014-15. The Grounds Of Appeal Raised By The Assessee Are As Under : Sanjay Kisan Chopde [A]

Section 143(3)Section 271

194C unlike in this case wherein the said party had deducted TDS at the rate of 10% under section 194J (a section applicable when payee is a professional/ technical service provider). It was also stated that, the entries in the TDS statement hosted by the Department are based on the TDS returns filed by the deductors and as such

SHRI SANJAY KUMAR SINGH ,NAGPUR vs. INCOME TAX OFFICER WARD 8(1), NAGPUR

Appeal is allowed in above terms

ITA 96/NAG/2020[2006-07]Status: DisposedITAT Nagpur23 Dec 2022AY 2006-07

Bench: Shri S. S. Godaraआयकर अपील सं. / Ita No.96/Nag/2020 िनधा"रण वष" / Assessment Year : 2006-07 Shri Sanjay Kumar Singh, Vs. Ito, Ward- 8(1), Nagpur. Hanshu Patel Building, Amravati Road, Wadi, Nagpur- 440023. Pan : Axbps9499K Appellant Respondent Assessee By None : Revenue By : Shri G. J. Ninawe Date Of Hearing : 02.11.2022 Date Of Pronouncement : 27.12.2022 आदेश / Order Per S. S. Godara, Jm: This Assessee’S Appeal For Assessment Year 2006-07 Arises Against The Cit(A)-2, Nagpur’S Order Dated 21.08.2019 Passed In Case No. Cit(A)-2/141/2013-14, Involving Proceedings U/S 143(3) R.W.S. 147 Of The Income Tax Act, 1961; In Short “The Act”. Case Called Twice. None Appears At Assessee’S Behest. The Very Factual Position Existed On All Previous Hearing As Well. He Is Accordingly Proceeded Ex-Parte.

For Respondent: Shri G. J. Ninawe
Section 143(3)Section 194CSection 40

3. Mr. Ninawe vehemently contended that the assessee ought to have deducted TDS on the ground that hire charges paid to various brokers without deducting TDS. He further quotes section 194C

RAGHAV AGRITECH,NAGPUR vs. ITO WARD 3(4), NAGPUR

In the result, appeal filed by the assessee is allowed

ITA 182/NAG/2024[2019-20]Status: DisposedITAT Nagpur18 Nov 2024AY 2019-20

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: NoneFor Respondent: Shri Vijay Agrawal
Section 139Section 143Section 143(1)Section 194CSection 1aSection 234ASection 40

TDS on payment of ` 2,06,50,000, to contractor for building construction has not been deducted and hence 30% of sum paid is disallowable under section 40(a)(ia) though the assessee had disallowed ` 3,09,750, being 30% of depreciation claimed by it. The assessee being aggrieved filed appeal before the first appellate authority. 5. The learned

DEPUTY COMMISSIONER OF INCOME TAX , CIRCLE-2, NAGPUR vs. M/S UNITED BUILDERS , BHANDARA

In the result, appeal filed by the Revenue is allowed

ITA 56/NAG/2020[2014-15]Status: DisposedITAT Nagpur14 Aug 2024AY 2014-15

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: NoneFor Respondent: Shri Kailash C. Kanojiya
Section 133(6)Section 143(3)

section 271(1)(c) of the Act was initiated separately. The assessee being aggrieved, carried the matter before the learned CIT(A). 7. The learned CIT(A), in view of the submissions made by the assessee, held that the action of the Assessing Officer in making the impugned addition is not found to be sustainable in the facts

M/S TAWARI TRADERS ,BULDHANA vs. INCOME TAX OFFICER WARD -2, KHAMGAON

In the result, appeal by the assessee stands dismissed

ITA 193/NAG/2019[2013-14]Status: DisposedITAT Nagpur04 Mar 2025AY 2013-14

Bench: Shri V. Durgarao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Rachit ThakkarFor Respondent: Shri Abhay Y. Marathe
Section 36Section 36(1)(iii)Section 40

3-5-2017) where it has approved the view of Hon'ble Calcutta High Court in the case of Commissioner of Income Tax v. Crescent Export Syndicate, which reads as under: 22. The same view was taken by a Division Bench of the Calcutta High Court in Commissioner of Income Tax v. Crescent Export Syndicate, (supra). It was held

INCOME TAX OFFICER WARD -1, AKOLA vs. M/S BALKRISHANA TRADERS , NAGPUR

In the result, all the appeals of Revenue are dismissed

ITA 1/NAG/2019[2008-09]Status: DisposedITAT Nagpur31 Oct 2023AY 2008-09

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

For Appellant: Shri Sanjay C. ThakarFor Respondent: Shri Kailash G. Kanojiya
Section 143(1)Section 148Section 194CSection 40

3. First, we shall take up appeal in ITA No.01/NAG/2019 for A.Y. 2008-09. 4. The Revenue raised three grounds of appeal amongst which the only moot question arises for our consideration is as to whether the CIT(A) justified in deleting the addition made by the AO for violation of non- deduction of tax u/s. 194C, consequently making disallowance

INCOME TAX OFFICERS WARD -1 , AKOLA vs. M/S BALKRISHANA TRADERS , AKOLA

In the result, all the appeals of Revenue are dismissed

ITA 3/NAG/2019[2010-11]Status: DisposedITAT Nagpur31 Oct 2023AY 2010-11

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

For Appellant: Shri Sanjay C. ThakarFor Respondent: Shri Kailash G. Kanojiya
Section 143(1)Section 148Section 194CSection 40

3. First, we shall take up appeal in ITA No.01/NAG/2019 for A.Y. 2008-09. 4. The Revenue raised three grounds of appeal amongst which the only moot question arises for our consideration is as to whether the CIT(A) justified in deleting the addition made by the AO for violation of non- deduction of tax u/s. 194C, consequently making disallowance

INCOME TAX OFFICER WARD -1, AKOLA vs. M/S BALKRISHANA TRADERS , NAGPUR

In the result, all the appeals of Revenue are dismissed

ITA 2/NAG/2019[2009-10]Status: DisposedITAT Nagpur31 Oct 2023AY 2009-10

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

For Appellant: Shri Sanjay C. ThakarFor Respondent: Shri Kailash G. Kanojiya
Section 143(1)Section 148Section 194CSection 40

3. First, we shall take up appeal in ITA No.01/NAG/2019 for A.Y. 2008-09. 4. The Revenue raised three grounds of appeal amongst which the only moot question arises for our consideration is as to whether the CIT(A) justified in deleting the addition made by the AO for violation of non- deduction of tax u/s. 194C, consequently making disallowance