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    <title>2026 (5) TMI 723 - ITAT MUMBAI</title>
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    <description>Ambulance-based emergency medical services were treated as specialised medical services rather than mere transport because the vehicles carried medical apparatus, medicines and emergency technicians for pre-hospital care and stabilisation; the payments to BVG were therefore held to fall under section 194J, not section 194C. By contrast, the contracts with HLL and FSMS involving sample collection, transport, storage, reporting and biomedical equipment maintenance were not sufficiently analysed on their actual terms, so the classification question under section 194J or section 194C was remanded for fresh examination. The governing principle is that TDS classification depends on the real and dominant nature of composite contractual services.</description>
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