C.I.T.,Delhi vs M/S.Bharti Cellular Ltd

The Supreme Court addressed whether M/s. Bharti Cellular Limited was required to deduct TDS under Section 194J of the Income Tax Act, 1961 when paying interconnect charges to BSNL/MTNL. The Court interpreted 'fees for technical services' as defined in Section 194J and Section 9(1)(vii), emphasizing that the term should be understood in a narrow sense, particularly in light of its context with managerial and consultancy services. The Court held that the absence of manual intervention in the technical operations of interconnection meant that TDS was not applicable in this case.