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We find that the Tribunal vide aforesaid order dated 18.11.2016, while deliberating the issue in hand that too in the case of assessee itself observed/held as under:

16. By the impugned order CIT(A) held that assessee has correctly deducted tax at source under section 194C, after observing as under:

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. Therefore, I agree with the appellant that in respect of these services/works outsourced, it cannot be said that the these parties have rendered any managerial, technical or consultancy services to the appellant within the SBI Life Insurance Company Ltd.

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 SBI Life Insurance Company Ltd.

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. Therefore, I agree with the appellant that in respect of these services/works outsourced, it cannot be said that the these parties have rendered any managerial, technical or consultancy services to the appellant within the meaning of Explanation 2 to Section 9(1)(vii) of the Act. These services involve carrying out of "work" within the meaning of the section 194C of the Act. The case laws cited by the appellant also support the contention of the appellant. The appellant has therefore, correctly deducted the tax at source under the said section 194C of the Act and provisions of section 194J are not applicable. I hold accordingly and the demand of Rs.

94,22,206/- raised by the AO in this regard is deleted.

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:

SBI Life Insurance Company Ltd.

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 SBI Life Insurance Company Ltd.