Sec. 40(a)(ia) & 194C of Income Tax Act, 1961— TDS— Provisions of section 194C cannot be said to be attracted as section 194C deals with deduction of tax at source when it comes to payment to contractors and in the case of assessee, neither the assessee nor M/s Prabhu Construction can be styled as contractors. It is obvious that the provisions of s. 194C of the IT Act were not attracted and since the provisions of s. 194C were not applicable, the consequent provisions of s. 40(a)(ia), will also not apply for making disallowance of the expenditure in computing the income under the head ‘income from business or profession’ —Asstt. CIT vs. Alfran Construction (P) Ltd. [2020] 313 CTR 365 (BOM)