This compilation indexes six rulings — spanning CESTAT benches, the Supreme Court of India, and the Authority for Advance Rulings — in which Section 194C of the Income Tax Act, 1961 was among the provisions cited. The cases range from service tax demand proceedings where Income Tax Department data (Form 26AS) was used as third-party evidence, to a criminal prosecution for non-remittance of TDS deducted under Section 194C, to an advance ruling on the tax treatment of payments to a non-resident publisher. The compilation is arranged in reverse chronological order of decision date and is intended as a structured research index for in-house tax teams, Big-4 associates, and law firm researchers.

Research index only. This page is a structured case-law reference, not legal or tax advice. Readers should verify all rulings against full judgment texts, check for subsequent stays or reversals, and consult qualified counsel before drawing conclusions for any specific fact pattern.

The statutory framework in one paragraph

Section 194C of the Income Tax Act, 1961 requires any person responsible for paying any sum to a resident contractor or sub-contractor for carrying out any work (including supply of labour) in pursuance of a contract between the contractor and a specified class of payors — including the Central Government, State Governments, local authorities, companies, co-operative societies, trusts, universities, and individuals/HUFs subject to tax audit — to deduct income tax at source at the rates prescribed in the section at the time of credit or payment, whichever is earlier. The deducted amount is required to be remitted to the Central Government within the prescribed time and in the prescribed manner under Rule 30 of the Income Tax Rules, 1962. Failure to deduct or failure to remit after deduction may attract interest, penalty, and, in certain circumstances, prosecution under the Act.

The 6 rulings

1. M M Group vs -Siliguri Commissionerate

Bench: Custom, Excise & Service Tax Tribunal
Date: 15 July 2025
Sections engaged: 194C, 66D, 66D(1)(iii)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (Service Tax Appeal No. 75950 of 2022 and Service Tax Appeal No. 75699 of 2023) was filed before the CESTAT Eastern Zonal Bench, Kolkata, arising out of orders-in-appeal passed by the Commissioner of Appeal, C.G.S.T. & C.X., Siliguri (Appeal) Commissionerate. The source preview indicates the matter was listed for a final order before the Regional Bench — Court No. 1; no further substantive reasoning is available in the source preview.

2. Power Tech vs Meerut-I

Bench: Custom, Excise & Service Tax Tribunal
Date: 22 April 2025
Sections engaged: 174, 194C, 70(1), 73(1), 77(2), 78
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (Service Tax Appeal No. 70380 of 2023) arose out of an order-in-appeal passed by the Commissioner (Appeals), Central Goods & Services Tax, Meerut, before the CESTAT Allahabad Regional Bench. Per the source preview, the appellant was registered for providing taxable services including works contract/construction services and erection, commissioning and installation services; on the basis of information received from the Income Tax Department under the third-party data exchange policy (Form 26AS), it was observed that the appellant had received a sum of Rs. 59,85,579/- on account of providing declared services, and on comparison with the ST-3 return for the relevant period, it was observed that the appellant had short-paid or not paid service tax in respect of consideration so received.

3. Jmk Housing And Security India Limited vs Lucknow

Bench: Custom, Excise & Service Tax Tribunal
Date: 10 March 2025
Sections engaged: 142, 174, 194C, 70, 73(1), 75, 77(1), 77(1)(b), 77(1)(d), 77(2), 78
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (Service Tax Appeal No. 70120 of 2023) arose out of Order-in-Appeal No. 1138-ST/APPL/LKO/2022 dated 09.12.2022 passed by the Commissioner (Appeals), Customs, CGST & Central Excise, Lucknow, before the CESTAT Allahabad Regional Bench. Per the source preview, the appellant is registered under Service Tax Registration No. AACCJ1703EST001 for providing "Manpower Recruitment/Supply Agency Services"; based on third-party information obtained from the Income Tax Department, it was revealed that the appellant had received a gross amount of Rs. 2,06,36,096/- during Financial Year 2016-17, and a demand-cum show cause notice dated 18.10.2021 was issued calculating service tax on those gross receipts at 15%.

4. M/S. Gammon India Ltd vs Commissioner Of Central Excise

Bench: Custom, Excise & Service Tax Tribunal
Date: 27 June 2014
Sections engaged: 194C, 76, 78
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter comprised five consolidated service tax appeals (Appeal Nos. ST/437/10-Mum., ST/374/11-Mum., ST/529/12-Mum., ST/759/12-Mum. & ST/87982/13-Mum.) before the CESTAT West Zonal Bench at Mumbai, arising out of multiple Orders-in-Original passed by the Commissioner of Central Excise, Nagpur. The source preview indicates the appeals were heard and decided on the same date, 27 June 2014; no further substantive reasoning is available in the source preview beyond the procedural listing.

5. Madhumilan Syntex Ltd. & Ors vs Union Of India & Anr

Bench: Supreme Court of India
Date: 23 March 2007
Sections engaged: 194C, 2(35), 245, 276B, 278A, 278B, 279
Outcome: Outcome not specified in source
Procedural / substantive ground: This criminal appeal (Appeal (Crl.) 1377 of 1999) was filed before the Supreme Court of India against an order of the High Court of Madhya Pradesh (Indore Bench) dated March 12, 1999, which had rejected in limine Miscellaneous Criminal Petition No. 4730 of 1998. Per the source preview, the respondents' case was that for Assessment Year 1989-90, though an amount of Rs. 1,29,348/- was deducted by the appellant-company as tax deducted at source, it was not credited to the account of the Central Government as required under the Act read with Rule 30 of the Income Tax Rules, 1962; the appellant-company (Madhumilan Syntex Ltd.) dealt in the production and business of yarn and its tax assessment was done by the Deputy Commissioner of Income Tax (Tax Assessment), Special Range No. 1, Indore.

6. In Re: Speciality Magazines (P) Ltd vs Unknown

Bench: Authority Tribunal
Date: 7 February 2005
Sections engaged: 194C, 245Q(1), 42, 5(2), 9(1)(i)
Outcome: Outcome not specified in source
Procedural / substantive ground: This application (AAR No. 610 of 2003) was filed under Section 245Q(1) of the Income Tax Act, 1961 before the Authority for Advance Rulings. Per the source preview, the applicant, M/s Speciality Magazines (P) Ltd. (SMPL), is an Indian company acting as advertisement concessionaire for M/s The Economist Newspaper Limited (TENL), a company registered in the United Kingdom that carries on business of publishing magazines from London and does not have a permanent establishment in India; the ruling concerned the tax treatment of amounts paid by SMPL to TENL in that capacity.

Patterns across these 6 rulings

Income Tax Department data as a trigger in service tax proceedings. In at least two of the CESTAT cases (cases 2 and 3), the source previews explicitly disclose that the demand proceedings were initiated on the basis of third-party information received from the Income Tax Department — specifically Form 26AS data reflecting amounts received by the appellants — which was then compared against their filed ST-3 returns to identify short-payment or non-payment of service tax.
Section 194C cited across multiple tax regimes and forums. Across these six rulings, Section 194C appears as a cited provision before CESTAT (a service tax forum), the Supreme Court of India (a criminal prosecution context), and the Authority for Advance Rulings (a direct tax ruling context). This cross-regime citation pattern reflects the section's role as a TDS source provision whose data flows into enforcement actions in adjacent tax frameworks.
Consolidated appeals arising from multiple Orders-in-Original. The Gammon India (case 4) matter involved five consolidated service tax appeals arising from multiple separate Orders-in-Original passed by the same Commissioner, illustrating the pattern of multi-period or multi-issue demand consolidation before CESTAT in service tax proceedings where Section 194C is among the cited provisions.
Criminal prosecution dimension. The Madhumilan Syntex matter (case 5) stands apart from the service tax appeals in that it engaged Section 194C in a criminal prosecution context, with the provisions relating to prosecution for failure to remit TDS deducted from contractor payments being the subject of the Supreme Court proceedings. This reflects a distinct enforcement pathway under the Income Tax Act that is separate from assessment or demand proceedings.
Outcome data limitations across the dataset. All six cases in this compilation carry the outcome designation "Outcome not specified in source," and the available text previews are predominantly procedural in nature. Researchers relying on this index for outcome analysis should obtain and review the full judgment texts from the source portals before drawing any conclusions.

How to use this compilation

This index is designed as a starting point for structured case research, not as a substitute for reading the full judgments. Each entry provides the tribunal or court, the date of order, the sections cited, and — where available in the source preview — the key procedural and factual background. Because all six cases carry outcome designations of "Outcome not specified in source," researchers must retrieve the complete judgment texts from indiankanoon.org or the relevant official court and tribunal portals to determine the actual disposition, the operative holding, and any directions issued.

Before relying on any ruling in advisory, compliance, or litigation work, researchers should verify whether the order has been stayed, reversed, or appealed to a higher forum subsequent to the date of decision. CESTAT orders may be appealed to the relevant High Court; Supreme Court judgments are final subject to review or curative petitions; AAR rulings bind only the applicant and may be appealed. Additionally, where a ruling predates legislative amendments — such as changes to service tax provisions post-GST implementation or amendments to the Income Tax Act — researchers should assess whether the statutory context in which the ruling was delivered remains operative.

Finally, researchers should cross-check applicable CBDT circulars, instructions, and notifications relevant to Section 194C (including threshold limits, rate schedules, and exemption conditions) that may have been issued after the date of the rulings indexed here, as administrative guidance can materially affect how statutory provisions are applied in current proceedings.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 194C & Service Tax: 6 CESTAT, Supreme Court & AAR Rulings