https://www.taxtmi.com/caselaws?id=218531 Transmission charges are analysed as consideration for use of a standard electricity transmission facility, not for technical services, because section 194J applies only where a human element and technical know-how are rendered or made available to the payer. On that reasoning, mere use of sophisticated transmission infrastructure does not attract tax deduction at source. SLDC charges are also discussed in terms of whether the payer receives managerial or technical services in its own sphere of work; where the charges represent reimbursement of actual expenses and no technical knowledge is made available, section 194J is said to be inapplicable. The note frames both items around the same test for fees for technical services. en-us Tue, 31 Jul 2012 00:00:00 +0530 Mon, 12 Nov 2012 17:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=218531 Transmission charges are analysed as consideration for use of a standard electricity transmission facility, not for technical services, because section 194J applies only where a human element and technical know-how are rendered or made available to the payer. On that reasoning, mere use of sophisticated transmission infrastructure does not attract tax deduction at source. SLDC charges are also discussed in terms of whether the payer receives managerial or technical services in its own sphere of work; where the charges represent reimbursement of actual expenses and no technical knowledge is made available, section 194J is said to be inapplicable. The note frames both items around the same test for fees for technical services. Case-Laws Income Tax Tue, 31 Jul 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=218531