Assessee had entered into an agreement with IGSPT for availing services. Assessing Officer held that services received by assessee were technical and professional in nature, hence, assessee should have deducted tax at source from above payments under section 194J. Commissioner (Appeals) and Tribunal ruled in favour of assessee, stating that agreement did not involve professional, managerial, or technical expertise but was merely a call centre service where service providers were engaged in handling customer complaints, and their employees were mostly graduates or undergraduates, following prescribed guidelines.  On appeal the Court held of work they discharged, hence could not be said to be perverse. Further, Tribunal had recorded that service providers to whom assessee made that findings of fact were supported by terms of agreement between assessee and IGSPT and other material on record, such as details of call service executives, their qualifications, and nature payments had already paid appropriate taxes by way of advance tax / self-assessment tax.N No question of law arises.  (AY. 2008-09)