Payment made to casual labourers working under direct control of contractor won't attract sec. 194C

IT : Where issue relating to payments to labourers without deducting tax at source was concluded in assessment proceedings under section 143(3) and no incriminating material relating to said issue was discovered in search, Assessing Officer could not disallow said payment under section 153A on basis of change of opinion that tax was required to be deducted while making payments in question