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2012 (6) TMI 234 - GUJARAT HIGH COURTTDS under Section 194-I or 194C - 'work' u/s 194C - contractors for rendering transportation services for goods and passengers by buses, cars, Sumos, Utility Vans, etc - Held that:- two explanations added to Sections 194-I and 194-C of the Act, it was never the intention of the legislature to overlap any of the items mentioned within the meaning of 'rent', by including the same within the meaning of 'work' under Section 194-C of the Act. - Since the agreement for carriage of goods by vehicles other than railways comes within the purview of explanation of 'work' within the meaning of Section 194-C of the Act. it is settled law that where two interpretations are possible, the one which is favourable to the assessee should be adopted. Tribunal below was quite justified in adopting the case of the assessee in the facts of the present case. Decided in favor of assessee. [Birla Cement Works (2001 (2) TMI 8 (SC) )]
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