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    <title>2014 (6) TMI 638 - ITAT MUMBAI</title>
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    <description>A stay of demand under sections 201 and 201A was considered where the central dispute was whether hospital payments to doctors fell under section 194J as professional fees or section 192 as salary. The assessee showed a prima facie arguable case that the arrangement was for professional and consultancy services rather than an employer-employee relationship. The fact that the doctors had already discharged tax on the same receipts was also relevant, supporting the view that recovery should not be enforced twice for the same income. On that basis, stay of the demand was granted pending disposal of the appeals.</description>
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      <link>https://www.taxtmi.com/caselaws?id=248734</link>
      <description>A stay of demand under sections 201 and 201A was considered where the central dispute was whether hospital payments to doctors fell under section 194J as professional fees or section 192 as salary. The assessee showed a prima facie arguable case that the arrangement was for professional and consultancy services rather than an employer-employee relationship. The fact that the doctors had already discharged tax on the same receipts was also relevant, supporting the view that recovery should not be enforced twice for the same income. On that basis, stay of the demand was granted pending disposal of the appeals.</description>
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