HC determined payments made to IGSPT for call center services...

HC determined payments made to IGSPT for call center services were subject to TDS under section 194C, not 194J. The agreement between parties involved basic call center operations performed by undergraduates/graduates following prescribed guidelines, rather than professional/technical services. Service executives handled subscriber complaints without requiring specialized expertise. CIT(A) and ITAT's concurrent findings established the services were routine operational support, not technical/professional in nature. Additionally, service providers had already paid appropriate taxes through advance tax/self-assessment. HC found no question of law arose, as factual findings were supported by agreement terms, staff qualifications, and work nature documentation. Original assessment order requiring TDS under section 194J was not sustained.