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)
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)]