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2022 (2) TMI 1239 - AT - Income TaxTDS u/s 195 - withholding of tax - payment of transponder service fees - nil withholding tax certificate on the payment of transponder services made to the service provider - AO rejected the application of the assessee holding that payment falls under the definition of “Royalty” both under the provisions of the Act as well as under DTAA between India and relevant country - HELD THAT:- Identical payments made for transponder services has been in M/S VIACOM18 MEDIA PRIVATE LIMITED [2022 (1) TMI 939 - ITAT MUMBAI] as not liable for withholding tax. - Decided against revenue.
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