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2019 (12) TMI 327 - AT - Income TaxTDS u/s 194J - Carriage Fees/ Channel Placement fees - Whether payments made for use/right to use of 'process' are 'royalty' as per Explanation 6 to section 9(1)(vi) ? - whether any obligation was cast upon the assessee to subject the “carriage fees” paid to the cable operators for deduction of tax at source under Sec.194J, or not? - HELD THAT:- Hon’ble High Court of Bombay in the case of CIT, TDS-2, Mumbai Vs. UTV Entertainment Television Ltd. [2017 (11) TMI 915 - BOMBAY HIGH COURT] had observed, that in case of an assessee carrying on the business of broadcasting television channels, the payments made towards placement charges would fall within the meaning of “work” covered in Clause (iv) of Explanation to Sec.194C. On the basis of our aforesaid observations, we are of the considered view, that the CIT(A) had rightly vacated the disallowance that was made by the A.O under Sec. 40(a)(ia) - Appeal filed by the revenue is dismissed.
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