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2019 (3) TMI 1154 - AT - Income TaxTDS u/s 194J - payments to the Distributors of the Films constitutes fee for professional or technical services or royalty - Addition u/s 40(a)(ia) - HELD THAT:- Assessee is in the exhibition of films procured from distributors on revenue sharing basis. The Revenue shared by the assessee with the distributor to exhibit the cinematographic film is outside the scope of expression ‘royalty’ under Clause (v) to Explanation 2 to Section 9(1)(vi) of the Act referred to under the provisions of Section 194J of the Act. Therefore, such payment to distributor does not call for deduction of TDS. Section 40(a)(ia) of the Act do not come into play for disallowance of the expenses incurred by the assessee for exhibition of films. - Decided in favour or assessee.
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