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2015 (10) TMI 247 - AT - Income TaxTDS liability on advertisement - falls within the purview of section 194C and not section 194I? - Held that:- t it is an undisputed fact that assessee has entered into a contract with M/s Portland India Outdoor Advertising Pvt Ltd and Poster Publicity Division of Media-edge (CIA India Pvt Limited) (payee firms) for display of advertisement of its clients. These payee firms in turn obtained display services for displaying advertisement on hoardings sites etc., taken from the hoarding contractors/service providers/Municipal Corporation etc. There is no contract between the assessee and these two payee firms for providing any space/land/building, machinery etc. so as to fall in the realm of “rent” as stated in section 194I. Here it is a pure case of advertising contract for which TDS has rightly been deducted u/s 194 C. The finding of the CIT(A) as recorded above are based on correct appreciation of facts, law and the clarification issued by the CBDT and accordingly same is affirmed. Thus grounds raised by the revenue are dismissed in both the years. - Decided in favour of assessee.
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