Held, that the registration number of trucks/truck owner would not be relevant for the purpose of deciding the applicability of section 194C as it was the personnel/truck operator from whom the trucks were hired. Denying the deduction under section 40(a)(ia) on the premise that the aggregate of the amount paid by the assessee with the different truck drivers exceeded Rs. 50,000 could not be countenanced as the contract could not be with the trucks, it was with the personnel or driver of the truck or truck operators. Bringing the assessee under the ambit of section 194C to deny the deduction under section 40(a)(ia) was not supported by material evidence. The truck operators if not the truck owners, could not be considered as the sub-contractors for the purpose of section 194C(2). The orders of the Tribunal and the authorities were set aside and the matter was remanded to record a finding after examining the contract if any, entered into by the assessee with the truck owners or operators. Matter remanded. (AY.2008-09)