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2015 (10) TMI 2844 - AT - Income TaxTDS u/s 194J - Non deduction of TDS on “Portfolio Management Fees” - addition u/s 40(a)(ia) - HELD THAT:- We find that the Co-ordinate Bench of Tribunal in the case of Hiren Valves Pvt. Ltd.. [2014 (9) TMI 1275 - ITAT AHMEDABAD] on identical issue has held that only the services rendered by a person in the course of carrying out listed professions and other notified professions constitutes “fee for professional services” and only the payment in connection with those services attract the provision for Section 194J. Revenue has not pointed any distinguishing features in the present case and that of Hiren Valves (supra) nor has demonstrated as to why the aforesaid decision rendered by the Co-ordinate Bench could not be applied to the facts of the present case. We therefore, hold that no disallowance of expenses u/s. 40(a)(ia) in respect of payment of management fees was called for in the present case. We therefore direct its deletion. Thus the ground of Assessee is allowed.
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