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2011 (10) TMI 21 - AT - Income TaxPayment made pursuant to the contracts - Nature of security services - Technical services - TDS u/s 194C or 194J - Assessee in default - Circular No 715 dated 8/8/1995 - Held that:- the services provided by security personal under a contract with the agency cannot be categorized as technical service unless the provisions of Clause (vii) to Explanation 2 to Section 9(1) are fulfilled. A payment to be covered u/s. 194J should be fees for technical services and such fees should be for rendering of any technical, managerial or consultancy services and not anything else. - the payments made by the assessee to security services are covered u/s. 194C and there is no scope for applying the provisions of Section 194J.
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