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2015 (1) TMI 969 - GUJARAT HIGH COURTDeduction of TDS - contracts pertaining to hiring agreement OR rental agreement - 194-C v/s 194-I - Held that:- We cannot accept the contention of the learned Counsel that if the Tribunal has recorded any erroneous finding of fact or has not properly interpreted the terms of the agreement, such would fall in the arena of substantial question of law. As such, the scope of appeal under Section 260-A of the IT Act is limited to the substantial question of law and cannot be considered based on any question of fact. The Tribunal was satisfied on facts that it was hiring agreement and not rental agreement. Such finding of fact cannot be re-examined by us in the appeal under Section 260-A on the ground as sought to be canvassed. In our view, the scope of applicability of Section 194-C and Section 194-I are different, for which no substantial question arises for interpretation or for examination before this Court. Appeal dismissed. - Decided against revenue.
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