TDS Not Applicable: Revenue Sharing in Multi-Entity Model Not a Contract Payment u/s 194J of Income Tax Act.

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....TDS U/s 194J - sharing of fees - payments made by the appellant to ITGK for its share in RS-CIT course fees - the act of sharing of revenue in a multi entity business model cannot be held as contract payments and taking the logic further they cannot be held as payments on account of rendering of any professional or technical services as contemplated by Section 194J - AT....