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2019 (10) TMI 910 - AT - Income TaxTDS u/s 195 - Payment for transponder charges - whether the payment made by the assessee amounts to royalty and liable to the provisions of TDS or not, and interpretation of provisions pertaining to Indo-US DTAA? - AO held that the assessee has failed to comply the provisions of TDS on the payment made to M/s Intelsat Corporation USA on account of payment of transponder charges for the satellite facility provided - HELD THAT:- No disallowance u/s 40 (a) (i) can be made on account of “programming cost” paid to various non-residents and also payments made to PanAmSat and other non-residents. See NEW SKIES SATELLITE BV, SHIN SATELLITE PUBLIC CO. LTD. [2016 (2) TMI 415 - DELHI HIGH COURT] and TAJ TV LTD., C/O. M/S. SURESH SURANA AND ASSOCIATES [2016 (12) TMI 1291 - ITAT MUMBAI] - Decided against revenue.
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