Dismissing the appeal of the revenue the Tribunal held that n absence of express or implicit contract between the assessee and the maistries, payments made to the laborers through masteries / group leaders did not attract deduction at source hence no disallowances can be made. (AY. 2012-13)
ACIT v. Kasiviswanadham (A)(2018) 66 ITR525 (Vishakha)(Trib)
S. 40(a)(ia) : Amounts not deductible-Deduction at source– Contractor – In absence of express or implicit contract between the assesse and the maistries, payments made to the labourers through maistries / group leaders did not attract deduction at source hence no disallowances can be made. [S. 194C]