Call centre service payments treated as contract work, with no substantial question of law arising from concurrent facts.

Payments under a call centre services agreement were analysed as contractual service payments rather than professional, managerial, or technical fees. On the facts recorded by the lower authorities, the service model and evidence on record supported application of tax deduction at source provisions for work contracts rather than section 194J. The concurrent findings were reasoned and not shown to be perverse or unsupported by evidence, so they did not generate any substantial question of law. The material therefore points to Section 194C treatment and no legal issue surviving from the factual conclusions.

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Issues: (i) Whether the payments made under the agreement were liable to tax deduction at source under Section 194J of the Income-tax Act, 1961, or fell within Section 194C of the Income-tax Act, 1961. (ii) Whether any substantial question of law arose from the concurrent factual findings recorded by the lower authorities.

Issue (i): Whether the payments made under the agreement were liable to tax deduction at source under Section 194J of the Income-tax Act, 1961, or fell within Section 194C of the Income-tax Act, 1961.

Analysis: The concurrent findings recorded by the appellate authorities were that the agreement related to call centre services and did not involve the provision of professional, managerial, or technical expertise services. Those findings were supported by the agreement and the material on record, including the nature and qualifications of the service executives and the manner in which the services were rendered.

Conclusion: The payments were not shown to fall under Section 194J of the Income-tax Act, 1961, and the finding that Section 194C applied was upheld.

Issue (ii): Whether any substantial question of law arose from the concurrent factual findings recorded by the lower authorities.

Analysis: The factual conclusions were concurrent, reasoned, and supported by evidence. They were not shown to be perverse or based on no evidence. Since the proposed question depended entirely on those factual findings, no substantial question of law survived for consideration.

Conclusion: No substantial question of law arose.

Final Conclusion: The appeal could not be entertained on merits because the decisive findings were factual and free from perversity, and the Revenue's challenge failed.

Ratio Decidendi: Concurrent findings of fact, when supported by evidence and free from perversity, do not give rise to a substantial question of law.

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