The person taking the hoarding on rent has to deduct u/s 194I for the payment he makes to the owner of the hoarding (usually the society of the office buildings or residence building or the mall owner). When the person who has taken hoarding on rent displays ad of another person then it is an advertisement contract u/s 194C. If the advertiser goes to the owner and takes the space on rent then he has to deduct u/s 194I. If he makes a contract for displaying ad then u/s 194 C.
In this case the bill is for rent of signages. This means that temporary possession / right for possession of the signages has been to the user. The owner is not providing the service of display of ad. The owner has given the space to the user to use it as he likes for two days at his risk and consequences and therefore section 194I should be applicable.
The transaction always evolves around the agreement and the intentions of the transacting parties and here it is apparent that the owner of the space is not assuming any responsibility of painting the advertisement or fixing it on the signage. He has clearly billed for rental.
Take an example of a vehicle. When you lease it to someone then 194I is applicable. When you ply it for hire (means the risk is yours while running it) then it is contract u/s 194C. Same principle applies here. The bill is clearly stating rent. Dilipji, you do not need anything reduced to writing to make it a rental agreement. Even an oral arrangement with a bill for rent received and accepted by you is as good as a 'deemed' agreement of an arrangement between two parties and since he has billed rent and you have accepted the bill, whether there is an agreement in writing or not, your transaction is rent.
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