Dismissing the appeal of the revenue, the court held that payment to full time consultant doctors would fall within purview of S.194J as fees for professional services, and not under S. 192 as salary. (Followed CIT v. Grant Medical Foundation (2015) 375 ITR 49 (Bom.)(HC)
CIT v. Asian Heart Institute and Research Centre (P.) Ltd. (2019) 262 Taxman 395 /(2020) 423 ITR 75 (Bom.)(HC)
S. 194J : Deduction at source – Fees for professional or technical services –Doctors-Payment to full time consultant doctors would fall within purview of S.194J as fees for professional services, and not under S. 192 as salary. [S. 192]