JUDGMENT

Alok Aradhe, J. - This appeal under Section 260A of the Income Tax Act, 1961 (hereinafter referred to as the Act for short) has been preferred by the assessee. The subject matter of the appeal pertains to the Assessment years 2004-05 to 2009-10. The appeal was admitted by a bench of this Court vide order dated 03.09.2013 on the following substantial questions of law:

(i) The Hon ble Tribunal was right or justified in confirming the order passed by the CIT(A) in holding that the Appellant, a TPA, was required to deduct tax at source on payments made to hospitals under Section 194J of the Act?

(ii) The Hon ble Tribunal was justified in following the decisions of the Hon ble Bombay High Court in the case of Dedicated Health Care Service TPA (India) Pvt Ltd Vs ACIT, (2010) 324 ITR 345 (Bom.) and of the Hon ble Delhi High Court in the case of Vipul Medcorp TPA (P) Ltd., v. Central Board of Direct Taxes,2011 245 ITR 325 (Del.) in arriving at the above conclusion?

(iii) Circular No.8/2009 dated 24.11.2009 issued by the CBDT can be said to be in conformity with the provision contained in Section 194J of the Act?

(iv) The Hon ble Tribunal was correct in remanding the matter to the C