https://www.taxtmi.com/caselaws?id=339830 TDS characterisation depends on the substance of the contractual relationship and the applicable statutory or treaty framework. Remuneration paid to six engaged persons was treated as salary because the contracts reflected employee-like control, fixed monthly pay, reporting lines, leave and termination terms, so tax was deductible under section 192. Post-production services, including processing and digital mixing, were treated as work contracts under section 194C rather than professional or technical services under section 194J; for the Singapore recipient, the payment was also held not taxable in India under the India-Singapore DTAA because no technical knowledge was made available and there was no PE. Hotel room payments on an as-available basis were not treated as rent under section 194I. en-us Tue, 28 Feb 2017 00:00:00 +0530 Wed, 08 Mar 2017 06:58:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=339830 TDS characterisation depends on the substance of the contractual relationship and the applicable statutory or treaty framework. Remuneration paid to six engaged persons was treated as salary because the contracts reflected employee-like control, fixed monthly pay, reporting lines, leave and termination terms, so tax was deductible under section 192. Post-production services, including processing and digital mixing, were treated as work contracts under section 194C rather than professional or technical services under section 194J; for the Singapore recipient, the payment was also held not taxable in India under the India-Singapore DTAA because no technical knowledge was made available and there was no PE. Hotel room payments on an as-available basis were not treated as rent under section 194I. Case-Laws Income Tax Tue, 28 Feb 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=339830