TDS Under Section 194J Upheld for Coaching Institute Faculty

Brilliant Study Centre Private Limited Vs ITO (TDS) (ITAT Cochin) The ITAT Cochin held that payments made by a coaching institute to faculty members engaged for imparting coaching in competitive examinations were liable for tax deduction under Section 194J as professional fees and not under Section 192 as salary. The Tribunal observed that although the institute exercised administrative control over attendance, working hours, leave, and exclusivity, such supervision was necessary for efficient management and did not establish an employer-employee relationship. The faculty members were referred...