Applicability of Provisions of Section 194C to the payments to Calcutta Dock Labour Board (CDLB)

Assessee has made payments to the CDLB for supply of these workers. As long as the assessee has made payments to the CDLB for supply of labour, even when this labour may be treated as employed by the assessee for all practical purposes, the provisions of Section 194 C are clearly attracted. In such a situation, i.e. when labour hired by the assessee through CDLB is considered to be in assessee’s employment, the payments made to CDLB cannot be treated as payments for ‘any work’ , but nevertheless these payments could still be covered by the provisions of Section 194 C because these are pa...