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Payment Not Subject to TDS u/ss 194H or 194J; No Commission or Managerial Service Involved.
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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 as held by the ld. CIT(A). - AT....
TaxTMI