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Roaming charges paid by telecom operators to other operators constitute "fees for technical services" u/s 194J, attracting TDS obligation, as human intervention and technical expertise are integral and indispensable components for smooth, efficient, uninterrupted roaming services encompassing coordination, troubleshooting, customer support, billing, and network selection/activation. Roaming service is not mere connection but seamless service requiring continuous human monitoring and expertise. Tribunal erred by restricting consideration to initial connection stage, overlooking entirety of roaming period and human intervention aspects. Matter remanded to Tribunal for fresh consideration considering all relevant factors and Apex Court directions in Bharati Cellular case.
Roaming charges paid by telecom operators to other operators constitute "fees for technical services" u/s 194J, attracting TDS obligation, as human intervention and technical expertise are integral and indispensable components for smooth, efficient, uninterrupted roaming services encompassing coordination, troubleshooting, customer support, billing, and network selection/activation. Roaming service is not mere connection but seamless service requiring continuous human monitoring and expertise. Tribunal erred by restricting consideration to initial connection stage, overlooking entirety of roaming period and human intervention aspects. Matter remanded to Tribunal for fresh consideration considering all relevant factors and Apex Court directions in Bharati Cellular case.
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