Relationship of master and servant not necessary to claim deduction under 80I

Workers working under contractor and not under the assessee company are to be be treated as employees u/s 80I(2)(iv) for the purpose of claiming deduction u/s 80I of the Income Tax Act, 1961. The appellant concededly employed and utilised the services of workers through the contractor Buta Singh. At the relevant time during the assessment year 1986-87, the appellant employed 18 workers including those supplied by labour contractor. It claimed a deduction under Section 80I to the extent of Rs.92,251/- being 25% of the profit i.e. Rs.3,69,005.00. The AO declined it and included the amount in the...