2019 (6) TMI 1165

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.... Shah & Co for the Respondent   P.C.: 1. Revenue is in the appeal against the judgment of the Income Tax Appellate Tribunal, Mumbai ("the Tribunal" for short) dated 22.6.2016. 2. Following question is presented for our consideration:- "Whether on the facts and in the circumstances of the case and in law, the Tribunal was justified in holding that tax was deductible from paym....

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.... relates to a different payment and we shall therefore examine each question separately. 3. Respondent-assessee is an Insurance Company. Question Nos. a and b pertain to a deduction of tax at source on the payment of outsourcing expenses. The assessee had deducted tax under Section 194C of the Act. The revenue argues that the same ought to have been under Section 194J of the Act since pay....