Vidal Health Insurance TPA (P.) Ltd. v. JCIT (2020) 182 ITD 30 (Bang.)(Trib.)

S. 194J : Deduction at source-Fees for professional or technical services-Toll Free Telephone charges-Liable to deduct tax at source. [S. 9(1)(vii)]

Assessee is Engaged in business of  providing third party administration (TPA ) services to Insurance companies which has  made payment towards toll free telecom charges for toll free Telephone number provided by  telecom operators whereby charges for calls made by  consumers to toll-Free number were borne by  assessee. The AO held that payment made by assessee for such services amounted to royalty under Section 9(1)(vi) and liable to deduct TDS. (Ay. 2011-12 to 2014-15)