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    <title>2019 (10) TMI 354 - ITAT VISAKHAPATNAM</title>
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    <description>TDS on lease-rental payments required factual verification of when the liability first accrued and whether the expense had already been booked and transferred to the payee, so the matter was remanded to the Assessing Officer for fresh consideration. Transmission and SLDC charges paid for use of the network were treated as rental in character, not as royalty or technical services, so section 194J did not apply and section 194I governed the deduction. A valid lower deduction certificate under section 197 bound the payer for the period covered, so deduction above the certified rate was not warranted. The assessee obtained relief on the lease-rental issue, while the revenue&#039;s challenge on the other issues failed.</description>
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    <pubDate>Fri, 04 Oct 2019 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=386870</link>
      <description>TDS on lease-rental payments required factual verification of when the liability first accrued and whether the expense had already been booked and transferred to the payee, so the matter was remanded to the Assessing Officer for fresh consideration. Transmission and SLDC charges paid for use of the network were treated as rental in character, not as royalty or technical services, so section 194J did not apply and section 194I governed the deduction. A valid lower deduction certificate under section 197 bound the payer for the period covered, so deduction above the certified rate was not warranted. The assessee obtained relief on the lease-rental issue, while the revenue&#039;s challenge on the other issues failed.</description>
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      <pubDate>Fri, 04 Oct 2019 00:00:00 +0530</pubDate>
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