Mere TDS certificate not conclusive evidennce for determining nature of payments

Brief Facts of the case-

• The Appellant is a company engaged in the business of execution of EPC (Engineering, Procurement and Commissioning) contract.
• For the AY under consideration (AY 2006-07), assessee filed its return of income on 13/11/06 declaring loss of Rs. 65,48,374.
• The appellant had obtained an EPC contract form Lanco Amarkantak Power Private Ltd., (LAPPL).
• For the year under consideration the appellant received advances of Rs. 14.49 crores from LAPPL in the months of July 2005 and March 2006 & by March 2006 the works w

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