(Per : HONOURABLE MR.JUSTICE V. M. SAHAI)
1. We have heard Mr. M.R.Bhatt, learned Senior counsel assisted by Ms.Mauna M.Bhatt, learned counsel appearing for the appellant.
2. Admit. We formulate the substantial question of law as under:
1. Whether the Appellate Tribunal has substantially erred in holding that payments to contractors for Annual Maintenance Contract is covered under the provisions of 194C of the Act and not as Technical and professional Fees under section194J of the Act ?
2. Whether the Appellate Tribunal has substantially erred in holding that payments to various pilots engaged on daily wages for bringing the vessels in and out of the port were covered under section 194C of the Act and not under section 194 I/J of the Act as held by the Assessing Officer ?
3. Whether the Appellate Tribunal has substantially erred in holding that payments to various Taxes and tug hired charges were covered under section 194C of the Act and not under section194 I/J of the Act as held by the Assessing Officer ?
3. Issue notice to the respondent. Paper book be filed within three months.
(V.M.SAHAI,J) (N.V.ANJARIA,J) ***vcdarji Top