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Whether in the facts and circumstances of the case and in law, the Tribunal is justified in holding that the placement fees/carriage fees paid to Cable Operators/MSO/DTH Operators are payments for work contract covered under section 194C and not fees for technical services under section 194J, without appreciating that the services received by assessee are technical and managerial in nature?

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Section 194C of the Income-tax Act, 1961—Deduction of tax at source—Placement fees/carriage fees paid to Cable Operators/MSO/DTH Operators are payments for work contract covered under section 194C and not fees for technical services under section 194J.

Facts: Whether Tribunal is justified in holding that the placement fees/carriage fees paid to Cable Operators/MSO/DTH Operators are payments for work contract covered under section 194C and not fees for technical services under section 194J, without appreciating that the services received by assessee are technical and managerial in nature?

Held, that Tribunal is justified in holding that the placement fees/carriage fees paid to Cable Operators/MSO/DTH Operators are payments for work contract covered under section 194C and not fees for technical services under section 194J, without appreciating that the services received by assessee are technical and managerial in nature. - CIT V/s ZEE ENTERTAINMENT ENTERPRISES LTD. - [2018] 2 ITCD Online 117 (BOM)

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