Assessees were authorities appointed by and working under directions of the State Government with their main function to disburse honorarium/remuneration to teachers with whom colleges agree to perform teaching work entrusted by the college committee under the curriculum of the intermediate syllabus. Teachers were paid a fixed monthly honorarium/remuneration which did not exceed Rs.5 lakh. The AO held that the  payments made to such contract teachers fell within the definition of the expression ‘fee for professional services’ u/s. 194J and same were liable for deduction of TDS on payments made to contract teachers.  The Tribunal held that the words ‘fee for professional services, would not leave any scope for interpretation and categories mentioned therein as on date were exhaustive by explanation itself or by notification of CBDT and by necessary implication, such an exhaustive definition excludes payments made to contract teachers in intermediate colleges. Further, slab rates and rebates u/s. 87A, there would be no tax liability in the hands of teachers. Therefore, payments made to contract teachers did not answer the description of ‘fee for professional services’ and were not liable to TDS u/s. 194J. (Followed Notification No. 88/2008, dated 28-1-2008)(AY. 2020-21)