Dismissing the appeal of the revenue the Court held that, manufacture of goods as per specification, there is no principal, agent relation ship hence not liable to deduct tax at source. Accordingly no disallowances can be made. (Arising from ITA No. 2087/ M/2012 dt 23-03-2016 ) (ITA No. 953 of 2017 dt. 27-08-2019 (AY. 2009-10)
PCIT v. Sandu Pharmaceuticals Ltd. (2019) BCAJ-October-P. 65 (Bom.) (HC)
S. 40(a)(i) : Amounts not deductible-Deduction at source– Commission or brokerage–Manufacture of goods as per specification–No principal-Agent relation ship–Not liable to deduct tax at source-No disallowances can be made. [S. 194H].