2008 (8) TMI 526

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..... fficer raising a demand. The order upheld by Commissioner (Appeals). Tribunal found that as the assessee had not paid any amount to the procurement agencies on account of transportation, interest or storage charges as such, there was no liability for deduction of tax. Held that- if expenses incurred by a person on account of transportation, interest, storage etc. were added to the cost of the good .....

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..... ns 194A, 194-I and 194C were not applicable as no payment has been made separately on account of interest, rent, etc. The transaction was a transaction of purchase and sale and not payment of expenses ?" 2. The assessee in the present case is Food Corporation of India which is engaged in procurement of food grains for the Central pool. The food grains is procured through the State agencies and d .....

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..... not evident from there that the expenses so incurred by the procurement agencies were on behalf of the assessee rather it was found to be part of the cost at which the food grains were to be transferred by the procurement agencies to the assessee. With these facts, it was found that as the assessee had not paid any amount to the procurement agencies on account of transportation, interest or storag .....

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