Mere TDS certificate not conclusive evidennce for determining nature of payments

Brief Facts of the case- The Appellant is a company engaged in the business of execution of EPC (Engineering, Procurement and Commissioning) contract. For the AY under consideration (AY 2006-07), assessee filed its return of income on 13/11/06 declaring loss of Rs. 65,48,374. The appellant had obtained an EPC contract form Lanco Amarkantak Power Private Ltd., (LAPPL). For the year under consideration the appellant received advances of Rs. 14.49 crores from LAPPL in the months of July 2005 and March 2006 & by March 2006 the works were under progress. LAPPL had deducted TDS on the said amou...