Composite contract cannot be bifurcated to subject part of contract to higher TDS

Commissioner of Income Tax (Tds) And Another Vs Lalitpur Power Generation Co. Ltd. (Allahabad High Court) Allahabad High Court applying the principle of indivisibility of a composite contract held that contract cannot be bifurcated to subject a part of the contract to higher TDS. Facts- The assessee was engaged in business of generation of power. To set up that thermal power plant, the assessee entered into two sets of contracts. First, with Bharat Heavy Electric Ltd. (BHEL) to set up a Boiler Turbine Generator (BTG) and the second with Carbery Infrastructure Pvt. Ltd. (CIPL) to set up Balance...