The assessee made payments towards filling, unloading and other labour charges through head labourers. Since the labourers were directly employed by the assessee, were on its muster rolls and were covered by provident fund and Employees’ State Insurance benefits, the Tribunal held that payment through the head labourer was merely a mode of disbursement and did not create a contractual relationship attracting section 194C. Accordingly, no tax was deductible at source and the disallowance under section 40(a)(ia) was rightly deleted. (AY.  2010-11 to 2012-13).