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    <title>2012 (11) TMI 546 - ITAT BANGALORE</title>
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    <description>Transmission charges for use of standard electricity transmission facilities are characterised as payments not subject to tax deduction under section 194J where no technical service, human intervention, or technical know-how is provided to the payer. SLDC charges are analysed as reimbursement of actual expenses incurred by an independent statutory body rather than consideration for managerial or technical services, which would likewise place them outside section 194J. The stated treatment of SLDC charges is internally inconsistent, however, as they are also described as attracting section 194J. The governing distinction is between actual technical or managerial services and mere use of utility infrastructure or expense reimbursement.</description>
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    <pubDate>Tue, 31 Jul 2012 00:00:00 +0530</pubDate>
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      <title>2012 (11) TMI 546 - ITAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=218531</link>
      <description>Transmission charges for use of standard electricity transmission facilities are characterised as payments not subject to tax deduction under section 194J where no technical service, human intervention, or technical know-how is provided to the payer. SLDC charges are analysed as reimbursement of actual expenses incurred by an independent statutory body rather than consideration for managerial or technical services, which would likewise place them outside section 194J. The stated treatment of SLDC charges is internally inconsistent, however, as they are also described as attracting section 194J. The governing distinction is between actual technical or managerial services and mere use of utility infrastructure or expense reimbursement.</description>
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      <pubDate>Tue, 31 Jul 2012 00:00:00 +0530</pubDate>
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