https://www.taxtmi.com/caselaws?id=766664 Payments under a call centre services agreement were analysed as contractual service payments rather than professional, managerial, or technical fees. On the facts recorded by the lower authorities, the service model and evidence on record supported application of tax deduction at source provisions for work contracts rather than section 194J. The concurrent findings were reasoned and not shown to be perverse or unsupported by evidence, so they did not generate any substantial question of law. The material therefore points to Section 194C treatment and no legal issue surviving from the factual conclusions. en-us Wed, 26 Feb 2025 00:00:00 +0530 Sat, 01 Mar 2025 08:25:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766664 Payments under a call centre services agreement were analysed as contractual service payments rather than professional, managerial, or technical fees. On the facts recorded by the lower authorities, the service model and evidence on record supported application of tax deduction at source provisions for work contracts rather than section 194J. The concurrent findings were reasoned and not shown to be perverse or unsupported by evidence, so they did not generate any substantial question of law. The material therefore points to Section 194C treatment and no legal issue surviving from the factual conclusions. Case-Laws Income Tax Wed, 26 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766664