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2015 (2) TMI 532 - AT - Income TaxDisallowance u/s 40(a)(ia) - payments for purchase of activation card from TV channels attract TDS provisions u/s 194C - Held that:- AO has noted that the assessee has paid an amount of ₹ 36.15 lakhs to various TV channels. If that is the case, then nothing remains payable by the assessee by the end of the relevant financial year. Accordingly the ratio laid down by the ITAT Visakhapatnam Special Bench in the case of Merillyn Shipping & Transport vs. Add CIT (2012 (4) TMI 290 - ITAT VISAKHAPATNAM ) squarely applies to the facts of assessee’s case. We direct AO allow the expenditure of ₹ 35,69,715/-, if it is found to have been paid within the relevant financial year - Decided in favour of assessee by way of remand.
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