C.I.T-4 Mumbai vs M/S Kotak Securities Ltd

The Supreme Court upheld the Bombay High Court's ruling that transaction charges paid to the Bombay Stock Exchange constitute 'fees for technical services' under Section 194J of the Income Tax Act, 1961, necessitating TDS deduction. The Court clarified that the disallowance of these charges under Section 40(a)(ia) was incorrect due to a mutual understanding regarding TDS liability since 1995. Consequently, the appeal by Kotak Securities Ltd. was partly allowed, affirming the High Court's decision on the nature of transaction charges while addressing the Revenue's challenge.