INCOME TAX OFFICER(TDS), ALAPPUZHA vs. MUTHOOT HEALTH CARE PRIVATE LIMITED, KOZHENCHERRY

ITA 517/COCH/2025Status: DisposedITAT Cochin27 October 2025AY 2018-19Bench: SHRI INTURI RAMA RAO (Accountant Member), SHRI RAHUL CHAUDHARY (Judicial Member)1 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the CIT(A)'s decision, finding that the doctors were engaged as independent professionals under a 'contract for service'. Key factors included their freedom to practice elsewhere and lack of employee benefits.

What were the facts?

The Revenue appealed against the CIT(A)'s order which deleted the demand raised under Section 201(1) & 201(1A) of the Income Tax Act. The dispute was whether payments to doctors were salary (Section 192) or professional fees (Section 194J).

What were the issues?

The primary issue was to determine the nature of the relationship between the hospital and the doctors to ascertain the correct TDS provision applicable to payments made to them.

Which sections of the Income-tax Act were involved?

Section 201,Section 201(1A),Section 192,Section 194J

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Cases cited in this judgment(1)Show list

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Income Tax Appellate Tribunal, COCHIN BENCH, COCHIN

[ Per Rahul Chaudhary, Judicial Member:

1.

The present appeal preferred by the Revenue is directed against the order, dated 22/05/2025, passed by the Additional/Joint Commissioner of Income Tax (Appeals), Panchkula [hereinafter referred to as ‘the CIT(A)’] under Section 250 of the Income Tax Act, 1961 [hereinafter referred to as ‘the Act’] whereby the Ld. CIT(A) had allowed the appeal against the Assessment Order, dated 31/07/2021, passed under Section 201(1) & 201(1A) of the Act for the Assessment Year 2018-2019. 2. The Assessee has raised following grounds of appeal :

“1. The order of the AddI.CIT/ JCIT(Appea

The order continues below.

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