Assessee airlines collected passenger service fees comprised of security services charges and facilitation charges from its passengers and paid same to airport authority for providing such services and facilities to its passengers . On security service charges, assessee did not deduct tax at source  claiming that payment was actually made by assessee to CISF, a Government agency, for providing security services at airport hence provision of S.196 is applicable .  On facility component, assessee deducted tax at rate of 2 per cent. According to AO tax  at source was to be deducted on both abovesaid components of passenger service fees under S.  194J of the Act .  CIT (A) held  that tax at source was to be deducted on both abovesaid components under S.  194C. Tribunal held that security service fees was not paid by assessee to CISF directly but it was paid to airport authority, therefore, assessee could not take shelter under section 196 and, such payment was covered under section 194C, further, since facility charges collected by assessee were undeniably for service provided by airport operators to passengers of assessee airline, provisions of S.  194C would be applied to said payments . (AY. 2010 -11, 2011-12)