Court Rules TDS Liability on Passenger Service Fees u/s 194J, Exemption u/s 196 Not Applicable.

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....TDS u/s 194J - Tax deduction at source on the passengers’ services fees (PSF) - payment to CISF for security - assessee does not pay any sum to CISF but it is paid by the owners and operators of the airport - assessee cannot take shelter u/s 196 as the assessee is not payee to CISF but airport operators pay it - TDS liability confirmed.....