AO held that the assessee has failed to deduct tax at source in respect of honorarium paid to directors. Accordingly he disallowed the honorarium paid to directors,  which was affirmed by CIT(A.). Allowing the appeal of the assessee the Tribunal held that, honorarium paid was not ‘professional fee’ to be covered under provisions of S.194J of the Act. Even if it was to be considered as payment to director, provisions of s.194J(1)(ba) specified that any remuneration or fees or commission by whatever name called other than those on which tax was deductible u/s 192 to director of ‘company’ were covered by definition of fees for professional or technical services. Director referred to therein was not equivalent to ‘director’ of assessee. Company was different from co-operative society as they were defined u/s 2(17) and 2(19) separately. Just because person administering society was also referred to as director, provisions of S. 194J  could not be attracted to payment of honorarium made to director of assessee-society. Accordingly , there was no violation of S.194J of the Act . Tribunal also held  that the   assessee  had  produced evidence  showing that respective persons have  paid/filing returns of income and AO had not initiated any proceedings u/s 201 for violation of TDS provisions under any other provisions of Act, disallowance u/s 40(a)(ia) could not be sustained. ( AY.2013-14)