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2019 (5) TMI 229 - HC - Income TaxTDS u/s 194J - Channel Placement fees - Whether was not in the nature of Royalty as defined u/s.9(1) (vi) and so the tax is not required to be deducted u/s. 194J despite insertion of clarification by virtue of Explanation 6 in Section 9(1)(vi) w.e.f. 01.06.1976? - HELD THAT:- It is an agreed position between the parties that, the issue raised herein stands concluded in favour of the Assessee and against the Revenue by the decision of this Court in the Assessee's own case viz.CIT v/s. M/s. NGC Networks (India) Pvt. Ltd. [2016 (1) TMI 1368 - ITAT MUMBAI] . Thus, this question does not give rise to any substantial question of law. Thus, not entertained. Channel Placement fees u/s. 40(a)(ia) - TDS u/s. 194C or 194J - HELD THAT:- The issue raised herein stands concluded against the Revenue and in favour of the Assessee by the decision of this Court in CIT v/s. M/s. UTV Entertainment Television Ltd., [2017 (11) TMI 915 - BOMBAY HIGH COURT] rendered on 10/11th October, 2017. Thus, this question does not give rise to any substantial question of law. Thus, not entertained.
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