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6.16 The above activities mainly involve activities with reference to insurance policy documents, Inward/Outward sorting, documents scanning, putting documents in envelopes, record storage etc in respect of the life insurance business of the appellant. The charges per proposal for segregation of documents, preparation and dispatch etc are not very high. These parties have carried out the work in the normal course of their business and it is evident that the same does not involve very high technical or professional qualification. The work is repetitive in nature.

17. We have considered rival contention and found that the issue is squarely covered by the decision of coordinate bench in case of M/s Reliance Life Insurance Co. Ltd. (supra), wherein Tribunal observed as under:

9. We have heard both the parties and perused the orders of the Revenue Authorities as well as the relevant material placed before us.

From the orders of authorities below , rival submissions and records before us , we find that the assessee engaged in the life insurance business needs various types of services such as storage of data, scanning and sorting of documents, processing charges, call centre operations and business services besides other basic works connected and incidental therewith which were outsourced by the assessee to outside agencies on contractual basis. The various services outsourced were cash & bank reconciliation, commission querry handling, cash cheque collection charges , commission processing and document despatch, data processing, policy despatch, document scanning , printing ,emails of documents, infra support and outsourcing staffing, policy serving process, call inbound and outbound , tele-calling for answering customer queries about product , follow and maintaining dealers network etc. As is clear from the said outsourced services, these are a sort of clerical and basic administrative work. The assessee made the payment for these services after deducting TDS under the provisions of section 194C of the Act believing these are basic type of services involving no technical or professional qualification whereas the AO came to the conclusion that these are technical services and were required to be subjected to TDS under the provisions of section194J of the Act and finally treated the assessee in default under the provisions of section 201(1) of the Act and raised the demand accordingly. The ld CIT(A) after having examined and perused agreements with the service providers and after going into the various services provided reached a conclusion that the outsourced services do not require any kind of technical and professional expertise and are just simple and repetitive nature of work such as document storage, documents delivery and collection services and documents management services. The ld CIT(A) examined the contract with Writer Information Management Services and found that very basic services were contracted and rendered by the said party involving no special technical skill or professional qualification.On the basis of the rival arguments and perusal of the various records as placed before us we find that the work assigned to the service provider was not atechnical or professional work which required special skills but simple, basic and repetitive nature of workand we are inclined to opine that the order of CIT(A) is correct and deserved to be upheld.In view of the above facts, we dismiss the ground no 1raised by the revenue by upholding the order of FAA on this point.