This compilation indexes twelve income-tax rulings — spanning ITAT benches at Lucknow, Dehradun, Patna, Cochin, Cuttack, and Indore, and High Courts at Bombay, Uttarakhand, Rajasthan (Jodhpur), and Madras — that engage Section 194J of the Income Tax Act, 1961. The rulings range from February 2024 to February 2026 and are drawn from the TaxNoticeAI structured legal corpus. The compilation is designed to help in-house tax teams, Big-4 associates, and law-firm researchers locate primary source material on TDS disputes involving professional fees, technical services, and the recurring classification question of whether a given payment falls under Section 194C or Section 194J.

Research index only. This page catalogues publicly available court and tribunal orders for reference purposes. Nothing on this page constitutes legal or tax advice. Readers must consult the full text of each judgment and qualified professionals before drawing any conclusion.

The statutory framework in one paragraph

Section 194J of the Income Tax Act, 1961 requires any person (other than an individual or HUF not subject to tax audit) responsible for paying any sum to a resident by way of fees for professional services, fees for technical services, royalty, or non-compete fees to deduct income tax at the rates prescribed by the Finance Act for the relevant year, at the time of credit or payment, whichever is earlier. The section operates as a TDS mechanism, and a failure to deduct — or a deduction under a lower-rate provision such as Section 194C rather than the higher-rate Section 194J — can result in the payer being treated as an assessee in default under Section 201(1) of the Act. The boundary between "professional or technical services" (attracting Section 194J) and "contract payments" (attracting Section 194C) is the most frequently litigated issue in TDS jurisprudence, as reflected in the majority of rulings indexed below.

The 12 rulings

1. M/S Shivansh Infraestate vs Dy. CIT Range-6, Lucknow

Bench: Income Tax Appellate Tribunal - Lucknow
Date: 13 February 2026
Sections engaged: 145(3), 194J
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal was filed by the assessee against the order of the CIT(A), NFAC, passed under Section 250 of the Income Tax Act, 1961 on 18.01.2024, wherein the CIT(A) had partly allowed the assessee's appeal against the Assessing Officer's order dated 30.12.2017 (ITA No.106/LKW/2024, A.Y. 2015-16, PAN: AAQCS5896P). The source preview indicates the appeal involved various expense heads including business/sale promotion of Rs. 13,61,930/-, vehicle running and maintenance of Rs. 10,76,395/-, printing and stationery of Rs. 15,28,354/-, telephone expenses of Rs. 9,05,299/-, and travelling expenses of Rs. 6,75,655/-; the full substantive ground and final disposition are not determinable from the available source preview.

2. Dy. Commissioner Of Income Tax vs Halliburton Off Shore Services Inc

Bench: Income Tax Appellate Tribunal - Dehradun
Date: 11 February 2026
Sections engaged: 194C, 194J
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 241/DDN/2025, Assessment Year: 2021-22, PAN: AAACH5154M) arises from an order dated 30.09.2025 passed under Section 250 of the Act by the CIT(A), Noida-2. The Revenue challenged the CIT(A)'s action in granting relief to the assessee on account of alleged deduction of tax at source under Section 194C of the Act, whereas the Revenue's position was that tax ought to have been deducted under Section 194J of the Act; the final outcome of this classification dispute is not determinable from the available source preview.

3. Bijay Kumar Saraf, Daldali Bazar vs Dc/Ac Circle 1, Muzffarpur, It-Office

Bench: Income Tax Appellate Tribunal - Patna
Date: 30 January 2026
Sections engaged: 194C, 194J
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal by the assessee (ITA No.: 205/PAT/2025, Assessment Year: 2014-15, PAN: APDPS4735C) was filed against the order of the CIT(A)-NFAC, Delhi passed under Section 250 of the Act dated 25.02.2025. The appeal was heard at the Patna 'DB' Bench sitting at Kolkata (virtual court), with the hearing concluded on 06 January 2026; the specific ground concerning the classification of payments under Section 194C or Section 194J and the substantive outcome are not fully determinable from the available source preview.

4. Income Tax Officer(TDS), Alappuzha vs Muthoot Health Care Private Limited

Bench: Income Tax Appellate Tribunal - Cochin
Date: 27 October 2025
Sections engaged: 194, 194J
Outcome: Outcome not specified in source
Procedural / substantive ground: This Revenue appeal (ITA No. 517/COCH/2025, Assessment Year: 2018-2019, PAN: TVDM01878C) was directed against an order dated 22/05/2025 passed by the Additional/Joint Commissioner of Income Tax (Appeals). The source preview indicates the order touched on indicia of employment versus professional engagement, including fixed working hours, eligibility for employee benefits such as PF and gratuity, prohibition from engaging in other similar work, and disciplinary control — factors relevant to the distinction between salary (Section 192) and professional fees (Section 194J); the final disposition is not determinable from the available source preview.

5. The Commissioner Of vs Balabhai Nanavati Hospital

Bench: Bombay High Court
Date: 15 September 2025
Sections engaged: 192, 194J, 201(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: These consolidated Revenue appeals before the Bombay High Court (Income Tax Appeal Nos. 2166, 2448, 2451, 2612, 2758 of 2018 and 605 of 2020) challenged the order dated 8 September 2017 passed by the Income Tax Appellate Tribunal. The Revenue challenged the Tribunal's determination regarding the applicable TDS provision — whether payments made by the hospital were subject to Section 192 or Section 194J — with Section 201(1) consequences arising from the characterisation; the appeals were reserved on 13 August 2025 and pronounced on 15 September 2025, but the final outcome is not determinable from the available source preview.

6. Assistant Commissioner Of Income Tax vs Shiva Cement Limited, Rourkela

Bench: Income Tax Appellate Tribunal - Cuttack
Date: 26 August 2025
Sections engaged: 194J
Outcome: Outcome not specified in source
Procedural / substantive ground: These cross-appeals (ITA Nos. 388 & 392/CTK/2024 and CO Nos. 2 & 3/CTK/2025, for Assessment Years 2009-10 & 2010-11, PAN: AACCS4497A) were filed against orders of the CIT(A), Bhubaneswar-2, both dated 26.07.2024. The appeal was heard through virtual hearing at Kolkata on 01.07.2025; the source preview indicates the Tribunal described a single core issue arising in these proceedings, though the specific substantive ground and final disposition are not fully determinable from the available source preview.

7. Deputy Commissioner Of Income Tax vs Aster Dm Healthcare Limited, Ernakulam

Bench: Income Tax Appellate Tribunal - Cochin
Date: 15 July 2025
Sections engaged: 192, 194J
Outcome: Outcome not specified in source
Procedural / substantive ground: These four consolidated Revenue appeals (ITA Nos. 160, 161, 162 & 163/Coch/2025) cover Assessment Years 2018-19, 2019-20, 2020-21, and 2021-22 (PAN: AACCD7912K) and were directed against orders of the Addl/Joint Commissioner of Income Tax (Appeals), Bengaluru. The Tribunal noted that identical facts and issues were involved across all four years and accordingly disposed of the appeals in a consolidated order; the central dispute concerning the applicable TDS provision between Section 192 and Section 194J and the final outcome are not fully determinable from the available source preview.

8. Commissioner Of Income Tax vs Samsung Heavy Industries Company

Bench: Uttarakhand High Court
Date: 10 July 2025
Sections engaged: 40(a), 194C, 194J
Outcome: Outcome not specified in source
Procedural / substantive ground: This Income Tax Appeal (No. 10 of 2024) was filed by the Commissioner of Income Tax, International Taxation-3, New Delhi under Section 260-A of the Act, assailing the order dated 22.12.2023 passed by the Income Tax Appellate Tribunal, Dehradun in ITA No. 873/DEL/2017 for Assessment Year 2012-2013 (PAN: AAJCS7859K). Samsung Heavy Industries Company Limited had filed its return of income on 29.09.2012 declaring income of Rs. 51,79,380/-, and the return was selected for scrutiny assessment; the appeal involves the classification of payments under Section 194C versus Section 194J, with Section 40(a) disallowance consequences in issue, but the final outcome is not determinable from the available source preview.

9. Indian Institute Of Technology vs ACIT, TDS Circle, Patna

Bench: Income Tax Appellate Tribunal - Patna
Date: 19 February 2025
Sections engaged: 201(1), 194C, 194J
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (I.T.A. No. 107/Pat/2023, Assessment Year: 2013-14, PAN: PTNI00507D) arose from an order under Section 250 of the Act dated 07.03.2023 passed by the CIT(A)-NFAC, Delhi. The Assessing Officer had passed an order under Section 201(1)/1A of the Act alleging that IIT Patna had engaged M/s NBCC Ltd. for construction of an academic complex and paid a sum of Rs. 4,10,80,680/- without deducting tax at source; the dispute concerned whether the payments attracted Section 194C or Section 194J, but the final outcome is not determinable from the available source preview.

10. C.I.T. Udaipur vs M/S Hindustan Zinc Ltd

Bench: Rajasthan High Court - Jodhpur
Date: 3 September 2024
Sections engaged: 194C, 194J
Outcome: Outcome not specified in source
Procedural / substantive ground: These connected appeals before the Rajasthan High Court at Jodhpur (D.B. Income Tax Appeal No. 30/2012 and D.B. Income Tax Appeal No. 89/2014) involved the provisions of Section 194C and Section 194J. Learned counsel for both parties jointly submitted that the controversy stood covered by the judgment dated 19.10.2016 passed by the Jaipur Bench of the same court in D.B. Income Tax Appeal No. 422/2011; the source preview reproduces text of the statutory provisions of Section 194C and Section 194J as relied upon by counsel, but the final operative direction of the 2024 order is not determinable from the available source preview.

11. M/S. Idea Cellular Limited, Indore vs The DCIT (TDS), Indore

Bench: Income Tax Appellate Tribunal - Indore
Date: 1 August 2024
Sections engaged: 194J, 9(1)(vi), 9(1)(vii)
Outcome: Outcome not specified in source
Procedural / substantive ground: These three consolidated appeals by the assessee (PAN: AAACB2100P / TAN: BPLI00953B) were filed against three separate appeal-orders all dated 31.10.2014 passed by the CIT(A)-II, Indore, in Appeal Nos. IT-16/13-14/187, IT-173/13-14/188, and IT-241/13-14/189, arising in turn from orders dated 15.03.2013, 28.03.2013, and 30.07.2013 passed by the DCIT(TDS)/ACIT(TDS), Indore under Section 201(1)/(1A) of the Act for AY 2012-13 (FY 2011-12) and AY 2013-14 (Quarters 1–4 of FY 2012-13). The appeals involve Section 194J read with Section 9(1)(vi) and Section 9(1)(vii), indicating the dispute touches on the characterisation of payments as royalty or fees for technical services; the final outcome is not determinable from the available source preview.

12. Commissioner Of Income Tax vs M/S.Dishnet Wireless Limited

Bench: Madras High Court
Date: 17 May 2024
Sections engaged: 194J
Outcome: Outcome not specified in source
Procedural / substantive ground: These five consolidated Tax Case Appeals (Nos. 831, 832, 833, 836 and 838 of 2016) were filed by the Commissioner of Income Tax, Chennai under Section 260-A of the Act against a common order dated 20.07.2015 passed by the Income Tax Appellate Tribunal, Madras 'D' Bench, Chennai in ITA Nos. 322, 323, 324, 327, and 329/Mds/2014 (PAN: AAACD5767E). The appeals concern Section 194J, and the Madras High Court issued a common judgment; the substantive ground and specific outcome are not fully determinable from the available source preview.

Patterns across these 12 rulings

Section 194C vs Section 194J: the dominant classification battleground. The most frequently recurring issue across this set is whether a payment constitutes a "contract payment" attracting Section 194C or a "professional or technical services fee" attracting Section 194J. This dispute appears explicitly in cases 2 (Halliburton), 3 (Bijay Kumar Saraf), 8 (Samsung Heavy Industries), 9 (IIT Patna), and 10 (Hindustan Zinc), and is implicit in several others, making it the defining litigation theme in this compilation.
Salary vs professional fee boundary in healthcare and hospital sectors. Cases 4 (Muthoot Health Care), 5 (Balabhai Nanavati Hospital), and 7 (Aster DM Healthcare) all involve healthcare-sector entities and engage the question of whether payments to doctors or medical professionals should be treated as salary under Section 192 or fees for professional services under Section 194J. The Cochin bench handled two of these three disputes.
Section 201(1) default as the enforcement trigger. Multiple matters — including cases 5, 9, and 11 — arise because the Assessing Officer invoked Section 201(1) or Section 201(1A) to treat the deductor as an assessee in default, with the underlying substantive dispute concerning the correct TDS provision. This pattern illustrates that Section 194J disputes most often reach adjudication through the default-and-disallowance route rather than through primary assessment.
Multi-year and consolidated appeals are common. Several cases involve multiple assessment years heard together in a single consolidated order — notably cases 6 (AYs 2009-10 and 2010-11), 7 (AYs 2018-19 through 2021-22), 11 (AYs 2012-13 and 2013-14), and 12 (five ITAs) — suggesting that TDS classification disputes, once raised, tend to recur across successive years for the same assessee.
Revenue as appellant in a majority of cases. In cases 2, 4, 6, 7, 8, 9, 10, and 12, it is the Revenue (Department) that has preferred the appeal, typically seeking to substitute Section 194J for a lower-rate provision accepted by the first appellate authority. This pattern suggests that first appellate orders have frequently favoured assessees on the 194C/194J boundary, prompting Revenue appeals to tribunals and higher courts.

How to use this compilation

This index is a starting point for locating primary source material, not a substitute for reading the full judgment. Each entry above records only what is available in the structured source preview and identity fields; the full reasoning, findings on specific facts, and operative directions of each order will appear only in the complete judgment text, which should be retrieved from indiankanoon.org, the relevant court portal, or an authorised legal database. Always verify that the version you read is the final pronounced order and not a draft or incorrectly OCR-processed copy.

Before relying on any ruling for a compliance or litigation position, researchers should check whether the order has been stayed, appealed further, or reversed by a superior court. A tribunal order may have been challenged before the relevant High Court, and a High Court order may be pending before the Supreme Court; the citation of a ruling in this index does not represent a check on its current precedential status. Parallel CBDT circulars, instructions, and press releases on TDS under Section 194J — particularly those clarifying the scope of "technical services," "professional services," and the interaction with Section 194C after the 2020 amendment splitting Section 194J into two sub-categories — should also be reviewed alongside the case law.

When using this compilation for research on a specific industry or payment type, it is useful to note the court or tribunal hierarchy: Bombay High Court, Uttarakhand High Court, Rajasthan High Court, and Madras High Court orders carry binding effect within their respective jurisdictions, while ITAT orders are persuasive authority before co-ordinate benches and may be appealed to the relevant High Court under Section 260-A. Cross-jurisdictional persuasive value should be assessed with reference to whether the factual matrix and the statutory year (pre- or post-2020 amendment) are comparable.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 194C vs 194J TDS Classification: 12 ITAT and HC Rulings (2024–2026)