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2006 (11) TMI 159 - HC - Income TaxTDS "u/s 194C Or 194J" - Payments to outside producers for television programmes - HELD THAT:- We observe that Explanation III, which was introduced simultaneously with section 194J, is very specific in its application to not only broadcasting and telecasting but also include "production of programmes for such broadcasting and telecasting". If, on the same date, two provisions are introduced in the Act, one specific to the activity sought to be taxed and the other in more general terms, resort must be had to the specific provision which manifests the intention of the Legislature. It is not, therefore, possible to accept the contention of the Revenue that programmes produced for television, including "commissioned programmes", will fall outside the realm of section 194C, Explanation III of the Act. We find no infirmity in the view taken by the Tribunal which we hereby affirm. Thus, we hold that these appeals do not involve any substantial question of law. The appeals are accordingly dismissed.
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