
Case Law Analysis
|Income Tax Appellate Tribunal
Section 194J vs Section 192 | Hourly Coaching Faculty Are Independent Professionals, Not Employees: ITAT Cochin
The ITAT Cochin ruled that teachers paid hourly by coaching institutes without statutory benefits like PF, ESI, or appointment letters are independent professionals, not employees. This means TDS must be deducted under Section 194J for professional fees, not Section 192 for salary - a critical clarification for edtech firms and coaching centers nationwide.