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    <title>2009 (4) TMI 944 - ITAT JAIPUR</title>
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    <description>Wheeling, transmission and State Load Dispatch Centre charges paid for use of a regulated electricity transmission system were treated as reimbursement of regulated cost and not as fees for technical services. The text states that section 194J applies only where managerial, technical or consultancy services with human intervention are rendered, and mere use of an automated or sophisticated transmission network does not satisfy that test; the payments were therefore not subject to TDS under section 194J. It further states that interest under section 201(1A) is compensatory and was not leviable where the recipient had no tax liability, so no revenue loss arose from the alleged non-deduction.</description>
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      <title>2009 (4) TMI 944 - ITAT JAIPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=178796</link>
      <description>Wheeling, transmission and State Load Dispatch Centre charges paid for use of a regulated electricity transmission system were treated as reimbursement of regulated cost and not as fees for technical services. The text states that section 194J applies only where managerial, technical or consultancy services with human intervention are rendered, and mere use of an automated or sophisticated transmission network does not satisfy that test; the payments were therefore not subject to TDS under section 194J. It further states that interest under section 201(1A) is compensatory and was not leviable where the recipient had no tax liability, so no revenue loss arose from the alleged non-deduction.</description>
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