No TDS on payment for goods manufactured as per specification on principal-to-principal basis

DCIT Vs. P.Z. Cussons India (P) Ltd. (ITAT Mumbai)

Seminal features of the contract entered into by the assessee with the three concerns for purchase of goods clearly bring out that the contract for supply of goods is on principal-to-principal basis and is a contract for purchase of goods by the assessee and sale of goods by the respective manufacturers. No doubt, the manufacturers are obliged to manufacture products as per the specifications and standards provided by the assessee but it is a case where the

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