Section 194C TDS applicable on conversion of raw milk into processed milk & products

DCIT Vs Maahi Milk Producer Co. Ltd (ITAT Rajkot) The brief facts of the case the assessee is engaged in the business of selling milk and milk products. The assessee had made payment of Rs. 29,63,90,780/- to M/s. Mother Dairy and M/s. Giriraj Milk Pvt. Ltd. for conversion of raw milk into processed milk and milk products. On these payments the assessee made TDS under Section 194C of the Act at 2% treating these payments to be contract payments. Whereas the Assessing Officer on the other hand has held that these payments are in the nature of payments of technical services and the assessee ought...