TDS deductible on conveyance allowance by LIC to its Development Officers

Life Insurance Corporation of India Vs. ITO (TDS) (Orissa High Court) The short question that arises is whether LIC had a statutory obligation to deduct tax at source while paying the conveyance/additional allowance to its development officers? In support of the contention that conveyance/additional allowance are not income and therefore not liable for deduction of tax at source, LIC relies on a CBDT Circular dated 19th November 1986. The contention of the Department on the other hand is that in terms of instructions dated 18th March, 1991 the CBDT followed by another circular dated 23rd March...