TDS u/s 194C not deductible on security charges as it involves only supply of manpower

PCIT Vs ATC Telecom Infrastructure Pvt. Ltd. (ITAT Mumbai) ITAT Mumbai held that security charges involve supply of manpower only and the same does not involve “carrying on of any work”. Accordingly, provisions of section 194C are not attracted for expenses claimed as ‘security charges’. Hence, disallowance u/s 40(a)(ia) unjustified. Facts- The present name of the assessee is “M/s ATC Telecom Infra P Ltd”. Earlier it was known as Viom Networks Ltd and earlier to that, it was known as “Wireless TT Info Services Ltd (WTTIL). The company WTTIL was wholly owned subsidiary company of ...