No rendering of any services and the payment is not made for any managerial services to RCDF, therefore,...

No rendering of any services and the payment is not made for any managerial services to RCDF, therefore, payment can neither be held as liable for TDS u/s 194H of the Act as commission/ brokerage as held by the AO nor u/s 194J for rendering any managerial services as held by the ld. CIT(A). - AT .....

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