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2016 (2) TMI 923 - AT - Income TaxTaxability of advertisement revenue - Held that:- So far as the issue relating to addition on account of "advertisement revenue" and "distribution revenue" the same stands decided in favour of the assessee by the Tribunal, which has been affirmed by the Hon‟ble High Court in AY 1999-2000 and also in subsequent years. As regards the issue of "distribution receipts" treated as "royalty income", we find that this has been treated as business income and such a finding or conclusion now have attained finality, as pointed out by the Ld. Senior Counsel. Taxability on distribution revenue - Held that:- Since this issue has been decided in favour of the assessee by holding that the same is not taxable on the ground that it has been paid at Arm‟s length price, therefore, this ground becomes purely academic Taxability on distribution revenue and taxability of interest received u/s.244A - Held that:- As regards the issue relating to taxability of interest received u/s 244A, it is admitted that, so far as taxability of interest u/s 244 is concerned, under Article 11(4) of India Singapore Treaty, the same is now covered by the decision of the Hon‟ble Special Bench in the case of ACIT vs Clough Engineering Ltd, reported in [2011 (5) TMI 562 - ITAT, DELHI ].
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