K. SHIVASHANKAR BHAT ( 1 ) THE petitioners challenge the validity of the circular issued by the Central Board of Direct Taxes whereby the Board provided to extend the applicability of Section 194-C of the Income Tax Act. According to the petitioner their cases cannot be covered at all and therefore the circular is ultravires the provisions of the Act to that extent. ( 2 ) THE petitioners carry on the business of conducting and organising tours for international and a few domestic tours. They provide hotel accommodations, transport facilities, guides for local and other sight seeing and related services. When it is stated that they provide hotel accommodations, it should be understood that they did not render the hotel service as such but arrange for the accommodations in hotels for the tourists. ( 3 ) THE question is whether the petitioners "carry out any work" as contemplated under Section 194-C of the Act. It is clear that no tangible property is produced by the activity of the petitioners. They are actually rendering services of conducting tours or act as agents in providing accommodations. ( 4 ) THEIR cases cannot be in any way different from the cases of commission agents and brokers and following the decision of this court in M/s. S. R. F. Finance Limited Vs. Central Board of Direct Tuxes and others; reported in 1994 (IV) Apex Delhi 489, we declare that the impugned circular to the extent it purports to extend the provisions of Section 194-C to the activities of the petitioners as stated above is ultravires and unenforceable. The writ petition-is accordingly allowed. The rule made absolute. No costs.