The subsidy or financial support which was extended by the assessee to the concessionaire and was only envisaged to work as viability gap funding could not possibly have been construed as a payment made for work undertaken by the contractor. Though section 194C did not stand confined to works contract alone, unless the Revenue had established that the sum in question and represented by the viability gap funding were recompense for a physical activity undertaken or labour expended, the disbursements could not have formed the subject matter of withholding tax under section 194C of the Act.(AY. 2010-11 2011-12)