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    <title>2021 (11) TMI 34 - ITAT MUMBAI</title>
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    <description>The Tribunal upheld the Ld.CIT(A)&#039;s decision in favor of the appellant, ruling that payments for channel placement were not fees for technical services but should be treated as payments for work contracts under section 194C of the Act. As a result, the tax demand under section 201(1) of the Act was deleted. Additionally, the Tribunal agreed with the Ld.CIT(A) that interest under section 201(1A) was not applicable as the appellant had already deducted TDS under section 194C, leading to the deletion of interest amounting to Rs. 4,33,01,284.</description>
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      <title>2021 (11) TMI 34 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=414253</link>
      <description>The Tribunal upheld the Ld.CIT(A)&#039;s decision in favor of the appellant, ruling that payments for channel placement were not fees for technical services but should be treated as payments for work contracts under section 194C of the Act. As a result, the tax demand under section 201(1) of the Act was deleted. Additionally, the Tribunal agreed with the Ld.CIT(A) that interest under section 201(1A) was not applicable as the appellant had already deducted TDS under section 194C, leading to the deletion of interest amounting to Rs. 4,33,01,284.</description>
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