C.I.T.,DELHI vs M/S.BHARTI CELLULAR LTD.

The Supreme Court addressed the issue of whether TDS is deductible under Section 194J of the Income Tax Act, 1961 when Bharti Cellular Limited pays interconnect charges to BSNL. The Court emphasized that the term 'fees for technical services' must be interpreted narrowly, as per the rule of Noscitur a sociis, and highlighted the lack of expert evidence regarding manual intervention in technical operations. The Court held that further examination is necessary to determine the nature of services provided and the involvement of human intervention in the interconnection process.