Assessee vide two separate agreements had agreed with owners to undertake projects of construction of Complex and Plaza. Terms of those agreements do not indicate that assessee was appointed as merely a contractor to construct those projects.  AO held that provisions of S.  194C were attracted and assessee was obliged to effect tax deduction at source. CIT (A) as well as Tribunal deleted the addition. On appeal by the revenue the court held that  the assessee had merely engaged. its contractor.  neither assessee nor the contractor could be styled as contractors, not liable to deduct tax at source.  Order of Tribunal is affirmed.