Human interaction is a necessary factor for applicability of section 194J

The Bheemunipatnam Mutually Aided Cooperative Building Society Ltd. Vs ITO (ITAT Visakhapatnam) Chapter XVIIB of the Act covers the deduction of tax at source which includes section 194J also. The contention of the Ld. AR that when the provisions of section 195A are applied, applying the provisions of section 206AA is not valid due to the fact that the provisions of section 195A is very clear that the income shall be increased to such amount as would, after deduction of tax thereon at the rates in force for the financial year in which such income is payable, be equal to the net amount payable ...