Komorrah Limestone Mining Company Ltd. v. ACIT (2020) 203 TTJ 518 (Gauhati)(Trib.)

S. 40(a)(ia) : Amounts not deductible-Deduction at source-Payment to Tribal persons-Payments are not chargeable to tax-No disallowance can be made. [S. 10(26), 194C, 194I]

Amounts paid towards hiring of loader and excavator and land rent to Tribal persons not being chargeable to tax no disallowance can be made for failure to deduct tax at source. Referred Chandra Mohan Snku & Ors. v. UOI (2015) 118 DTR 65 / 276 CTR 385 (FB) (Tripura)(HC).  (AY. 2013-14)