Combined reading of provisions of sections 194C and 194J vis-a-vis C.B.D.T. Circular No. 720 makes it abundantly clear that payment made
to the C and F Agents, was for the services which was predominantly for "carrying out work", inter alia, relating to storage despatch, transportation, loading and unloading of goods, etc. Thus, deducted tax at source under section 194C of the Act.