DCIT (TDS) 3(2), Mumbai vs. Reliance Life Nsuranace Co. Ltd, Mumbai
The appeal of the revenue is dismissed
ITA 3011/MUM/2013[2010-11]Status: DisposedITAT Mumbai25 May 2016AY 2010-11
Bench: Shri Saktijit Dey & Shri Rajesh Kumar
For Appellant: Shri Jitendra B. SanghaviFor Respondent: Shri Pradeep Singh, DR
Section 131Section 133ASection 194CSection 194DSection 194ISection 194JSection 201(1)
…explained Explanation 2 to section 9(1)(vii) of the Act to support that the payment would not partake the character of fees for technical / managerial services. Assessee also relied on the decision of ITAT, Chennai in the case of R.S. Suriya vs. DCIT [2010] (2 ITR 746) (Chennai) which is relevant for the proposition that ‗management of the call sheets of the assessee could not be considered as professional services or technical services.......no professional qualification was required for giving such services and hence, there was no liability to deduct tax under section 194J .....‘. Assessee also relied on the C…