Dismissing the appeal of the revenue the Court held that where the payment made to services clerical in nature provisions of S.194C is applicable and not provision of S.194J the services cannot be held to be of technical or managerial services.
CIT v. Reliance Life Insurance Co. Ltd. (2019) 414 ITR 551 / 264 Taxman 296(Bom.)(HC)
S. 194C : Deduction at source–Contractors-Services clerical in nature-Not technical or managerial services-Provisions of S.194C is applicable and not S.194J [S. 194J]