Leased Line Charges Classified as "Royalty" u/s 9(1)(vi); No TDS Required u/s 194J Pre-Classification.

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....TDS u/s 194J - Since the leased line charges got the final dressing up as `Royalty’ u/s 9(1)(vi) of the Act after the close of the relevant Financial year, we have no hesitation in holding that - even though the amount became chargeable to tax as royalty in the hands of the recipient under the Act for the year under consideration - but the same did not fasten an obligation to deduct tax at source as the assessee could not have activated its sixth sense to ascertain beforehand that an obligation to deduct tax at source was in offing. - AT....