Bench: Shri R.K. Panda & Shri Laliet Kumar
194J(1) and as per section 40(a)(ia) of the Act which got amended with retrospective effect from 1.4.2006 wherein rent and royalty are introduced. Being so, the assessee is liable for deduction of TDS on the royalty payment. However, the Special Bench in the case of Merilyn Shipping & Transports (supra) held that the word "payable" used in section