Assessee's Internet Payment to Sify Ltd. Not Subject to TDS as Royalty Before 2012 Amendment (Sections 194I, 194J.

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....TDS u/s 194I or 194J - payment made by the assessee to M/s. Sify Ltd. towards internet charges - the said amendment was made by Finance Act, 2012 w.r.e.f. 01.6.1976. Thus, as per existing provision, when the assessee made the payment there was no liability to deduct tax at source by treating it as royalty. The amendment made with retrospective effect cannot fasten liability on the assessee.....