Section 194C TDS on payment for preparation & execution of advertisement content

Cowtown Software Design Pvt. Ltd. Vs DCIT (TDS) (ITAT Mumbai) It is not in dispute that assessee made payment to Ad agency i.e. Social Kinnect. We find from the perusal of the agreement with Social Kinnect and scope of services defined therein, Social Kinnect would engage various professional artists for preparation and execution of the advertisement content and Social Kinnect would provide ultimate advertisement content on behalf of the assessee in digital platform. We find that there is no direct connection or direct agreement between assessee company and the professional artists who had ass...