were not fees for
technical services and, therefore, the provisions of Section 194J
were not attracted and consequently the provisions of Section ... Explanation 2 to clause (vii) of
sub-section (1) of Section 9 ;
(c) ------
19) Explanation 2 to Section 9(1)(vii) reads thus
expenses under Section 40(a)(ia) of the Act
on account of not having suffered tax deduction at source
under Section 194J ... held that Section 194C of the Act is more
specific and is to be applied in preference to Section 194J of
the Act.
(iii) Section
hence, TDS ought
to have been deducted under Section 192 instead of Section 194J of the IT
Act.
11. As far as payment to these ... Assessee in default for
wrongly deducting tax under Section 194C instead of
Section 194J , would necessarily depend on the findings
given by the ITAT
hence, TDS ought
to have been deducted under Section 192 instead of Section 194J of the IT
Act.
11. As far as payment to these ... Assessee in default for
wrongly deducting tax under Section 194C instead of
Section 194J , would necessarily depend on the findings
given by the ITAT
hence, TDS ought
to have been deducted under Section 192 instead of Section 194J of the IT
Act.
11. As far as payment to these ... Assessee in default for
wrongly deducting tax under Section 194C instead of
Section 194J , would necessarily depend on the findings
given by the ITAT
hence, TDS ought
to have been deducted under Section 192 instead of Section 194J of the IT
Act.
11. As far as payment to these ... Assessee in default for
wrongly deducting tax under Section 194C instead of
Section 194J , would necessarily depend on the findings
given by the ITAT
hence, TDS ought
to have been deducted under Section 192 instead of Section 194J of the IT
Act.
11. As far as payment to these ... Assessee in default for
wrongly deducting tax under Section 194C instead of
Section 194J , would necessarily depend on the findings
given by the ITAT
hence, TDS ought
to have been deducted under Section 192 instead of Section 194J of the IT
Act.
11. As far as payment to these ... Assessee in default for
wrongly deducting tax under Section 194C instead of
Section 194J , would necessarily depend on the findings
given by the ITAT
Solutions
Ltd., TDS is required to be deducted under Section
194C and not under Section 194J of the Act?
(c) Whether on the facts ... Solution Ltd, TDS was required to be deducted
under Section 194C and not under Section 194J of the Act. Mr.
Suresh Kumar submitted that
clause (vi) of sub-section (1) of section 9 ;]
(c) where any sum referred to in sub-section (1) is credited to
any account, whether called ... deductible at source under section 194I and
there was no mention of Sections 194K or 194J being applicable.
18. He submitted that in the case
