Compensation to Services & Supplies India not subject to TDS as legal fee u/s 194J; Section 40(a)(ia) disallowance inapplicable.

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....Payment is on account of compensation not to M/s. Khaitan & Co. but to M/s. Services & Supplies India and this is not a legal fee necessitating deduction of tax at source as prescribed u/s. 194J of the Act. Once the provisions of section 194J of the Act are not attracted, the disallowance cannot be made u/s 40(a)(ia) - AT....