INCOME TAX : Where payee simply carried out a contractual work of up-linking and broadcasting programmes made or produced by assessee in electronic media by permitting assessee to avail benefit of requisite electronic set up against payment of fee as long as contract subsisted, facilities provided by payee did not amount to providing 'technical services' and, hence, payments could not be termed as fees for technical services under section 194J and would be liable to TDS under section 194C
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