Dismissing the appeal of the revenue the Tribunal held that ; Manufacture or supply of a product according to requirement or specification of a customer by using material which is purchased from a person other than such customer on the basis of principal to principal basis is not liable to deduct tax at source . (AY.2011-12)
DCIT v. Laboratories Griffon (P.) Ltd. (2018) 170 ITD 387 /65 ITR 317/193 TTJ 855/( 2019) 178 DTR 355 (Kol) (Trib.)
S. 194C : Deduction at source – Contractors -Principal to principal basis – Manufacture or supply of a product according to requirement or specification of a customer by using material which is purchased from a person other than such customer is not liable to deduct tax at source .