Commission to Sahayak for collecting milk liable for TDS u/s 194C

DCIT Vs M/s. Maahi Milk Producer Co. Ltd. (ITAT Rajkot)

Conclusion: Commission payments made by assessee to Sahayak was on percentage basis depending on various parameters like number of farmers pouring milk, fat and SNF factor in milk, quantity of milk collected etc. which ensured payment was commensurate with work performed and thus, the nature of work carried out by the Sahayak were covered by provisions of section 194C instead of section 194H and accordingly tax was deducted on the same accordingly.

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