Payment Not Subject to TDS: No Managerial Services Rendered u/ss 194H or 194J of Income Tax Act.

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....No rendering of any services and the payment is not made for any managerial services to RCDF, therefore, payment can neither be held as liable for TDS U/s 194H of the Act as commission/ brokerage as held by the AO nor u/s 194J for rendering any managerial services - AT....