Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2019 (12) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2019 (12) TMI 315 - ITAT MUMBAITDS u/s 194C OR 194J - Carriage Fees/Channel Placement fees - payments made for use/right to use of 'process' are 'royalty' as per Explanation 6 to section 9(1)(vi) - HELD THAT:- Hon’ble High Court of Bombay in the case of CIT, TDS-2, Mumbai Vs. UTV Entertainment Television Ltd. [2017 (11) TMI 915 - BOMBAY HIGH COURT] had observed, that in case of an assessee carrying on the business of broadcasting television channels, the payments made towards placement charges would fall within the meaning of “work” covered in Clause (iv) of Explanation to Sec.194C. On the basis of our aforesaid observations, we are of the considered view, that the CIT(A) had rightly vacated the disallowance that was made by the A.O under Sec. 40(a)(ia) of the Act.
|