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Rajasthan Knowldege Corp. Ltd., Jaipur vs Department Of Income Tax on 13 February, 2015

These activities were carried out by DLC. The certification has been given by the Vardhaman, Mahaveer Open University, Kota. The learner is required to deposit entire course fees @ Rs. 2300 for RS-CIT with the concerned ITGK, who received the sum on behalf of the stakeholders and also issued a receipt for the same. The 13 ITA No. 896/JP/2014 Rajasthan Knowledge Corp. Ltd. Vs. ITO TDS entire receipt from the learner by ITGK was deposited in the account of the assessee for the purpose of centralize collection and onward distribution of revenue shared out of the course fees as per collaboration between them. Rs. 2300/- is shared between various agencies as under:-
Income Tax Appellate Tribunal - Jaipur Cites 10 - Cited by 1 - Full Document

M/S. Hindustan Coca Cola Beverage Pvt. ... vs Commissioner Of Income Tax on 16 August, 2007

The assessee was carrying out these activities through various supporting agencies/centres like DLC, PSA & ITGKs. He further considered the word 'technical' with reference to fees for technical services and held that payment made to ITGK by the assessee falls under the category of technical service and is liable to be deducted TDS U/s 194J of the Act. The payment made to ITGK was claimed as sharing of income for course fees not expenditure. The assessee company for the purpose of its convenience, had categorized the said fees shared as marketing claim and infrastructure claim. After considering the CBDT's circular No. 275/201/95-IT(B) dated 29/01/1997 and the decision of Hon'ble Supreme Court in the case of Hindustan Coca Cola Beverages (P) Ltd. Vs. CIT 293 ITR 226 (SC) has held liable to be deducted TDS U/s 194J. Accordingly, he created demand U/s 201(1)/201(1A) as under:-
Supreme Court of India Cites 6 - Cited by 479 - B S Reddy - Full Document
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