TDS U/s. 194C applies on Bus rent paid by assessee school to transporter for carrying students

A careful consideration of the assessment order would reveal that AO while holding that assessee is liable for deduction of tax at source under the provisions of sec. 1941 of the Act has mainly rested his case on the ground that is the “rent” as defined in explanation u/s 1941 and the assessee has paid rent in respect of buses utilized by him being in the nature of plant.

In our opinion, simply for the reason that “rent” being explained under explanation given u/s 1941 in

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