Minimum guarantee payments - whether subject to TDS

Facts:

Assessee had to pay minimum guarantee fees to certain hotels/stays as they could not comply with the promised minimum volumes/revenues. No TDS was made on these payments. Revenue disallowed the spend for non-deduction of TDS under section 40a(ia). On appeal CIT(A) held that TDS was applicable under section 194-C and not under 194-I and sustained the disallowance. On higher appeal by the assessee -

Held in favour of the assessee that no TDS was obligated on the minimum guarantee payments. Disallowance was unwarranted. 

Case: Oravel Stays (P) Ltd. v. ACIT 2024 TaxPub(DT) 803 (Del-Trib)