Section 194J – Provision for legal and professional charges – where assessee made year end provision for payments towards legal and professional charges, since said provisions made at end of accounting year were reversed in the beginning of next year and neither payee nor exact amount payable were identifiable during year end and, further assessee had deducted tax at source in subsequent year on said payments in accordance with section 194J and also remitted same, no TDS was to be deducted on such payments by assessee during relevant year.
Subex Ltd. v. DCIT – [2023] 148 Taxmann.com 271 (Karnataka).