Dismissing the appeal of the revenue the Tribunal held that property in by-products came into ownership of millers from a point of coming of it into existence; hence, assessee was not owners of such by-products. Accordingly it was held that TDS provision is not attracted (AY.2012-13 , 2013-14, 2014-15)
ITO(TDS) v. Distt. Manager Punjab State Warehousing Corporation ( 2018) 54 CCH 164/ 196 TTJ 815/ ( 2019) 176 DTR 129 (Chd)( Trib)
S. 194C : Deduction at source – Contractors – Milling charges -property in by-products came into ownership of millers from a point of coming of it into existence-Assessee was not owners of such by-products—TDS provisions is not attracted . [ S.201 (1) 201(IA) ]