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2013 (7) TMI 691 - AT - Income TaxWhether CIT(A) has erred in deleting the addition made by the AO on account of adjustment in respect of arm's length price - the effort put in by the assessee for producing television serial or acquisition of television serial as per its own specifications and guidelines is much more than the acquisition of the exhibition rights of Hindi feature films which are already produced by others - more markup in the case of transfer of television software is justified as compared to transfer of exhibition rights of Hindi feature films - the TPO has not given any other comparable or reason for applying the markup of 15% on cost of Hindi feature films except that the assessee itself has applied markup of 15% in respect of transfer of television right - more markup in the case of transfer of television software is justified as compared to transfer of exhibition rights of Hindi feature films – appeal decided in favour of revenue.
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