Roaming Charges Not Liable for TDS under section 194J

DCIT – TDS Vs Reliance Communications Ltd. (ITAT Mumbai) The issue under consideration is whether the roaming charges paid by the assessee to the other telecom service provider are in the nature of ‘Fee for technical Services’ and hence liable for deduction of tax at source u/s 194J of the Act? ITAT states that, even if they consider the observations made by the Apex Court in the case of Bharti Cellular Ltd.supra, whether use of roaming service by one mobile service provider Company from another mobile service provider Company, can be termed as “technical services” or not...