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TDS u/s 194J - the payment made to resident towards annual license fee paid for the renewal of Microsoft software - Clause (ba) to the Explanation to section 194J provides that 'royalty' for the purpose of this section shall have the same meaning as given in section 9(1)(vi), hence the payer is liable to deduct tax at source u/s 194J - Failure to deduct TDS will entails disallowance u/s 40(a)(ia)