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2014 (6) TMI 410 - AT - Income TaxDisallowance u/s 40(a)(ia) of the Act TDS on Pay channel charges as royalty payment - Failure to deduct TDS u/s 194J of the Act Held that:- assessee cannot be held to be liable to deduct tax at source relying on the subsequent amendments made in the Act with retrospective effect. Though the Explanation 6 to sec. 9(1)(vi) inserted by Finance Act, 2012 is clarificatory in nature, yet in view of the fact that the view entertained by the assessee gets support from the decision of Delhi High Court, referred above, we are of the view that the assessee cannot be held to be liable to deduct tax at source from the Pay Channel Charges. - Decision in the case of Asia Satellite Telecommunications Co. Ltd. Versus Director of Income-tax [2011 (1) TMI 47 - DELHI HIGH COURT] followed Decided in favour of Assessee.
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