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2019 (6) TMI 1165 - HC - Income TaxShort deduction of TDS - TDS u/s 194C OR 194J - payment of outsourcing expenses such as processing charges and business services etc. - whether nature of services received by the assessee requires certain parameters of technical / managerial skill of highly specialized competency? - HELD THAT:- As decided in own case [2019 (6) TMI 547 - BOMBAY HIGH COURT] CIT (Appeals) and the Tribunal examined the nature of expenditure and came to the conclusion that the assessee had hired the services for various works such as storage of data, scanning of documents, processing charges, call centre operations etc. Looking to the nature of services outsourced, it was held that the same were basically clerical services of repetitive nature of work and payments were therefore, neither for managerial nor for technical services. Having perused the documents on record and looking to the nature of services described, we do not find that the Tribunal has committed any error. The work outsourced was in the nature of clerical work Charges of the event management paid by the assessee CIT (Appeals) and the Tribunal noted that the assessee had arranged conference at Agra. The payments were essentially for domestic ticketing, reimbursing hotel expenses, tour leaders’ expenses. Such services were essentially in the nature of travel agent who had arranged the ticket booking and hotel facilities. The Tribunal therefore held that payments were not for any technical services availed by the assessee. - Decided against revenue.
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