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2022 (3) TMI 965 - AT - Income TaxTDS u/s 195 - disallowance of online advertisement expenditure under section 40(a)(i) - whether online advertisement services are in the nature of royalty under section 9(1)(vi) of the Act on which TDS is applicable - HELD THAT:- We are of the opinion that the similar issue came up for consideration before the Tribunal in the case of Moonfrog Labs Pvt. Ltd.[2022 (1) TMI 1089 - ITAT BANGALORE] - Thus we remit the issue to the file of AO with similar directions. AO shall call for the Master Services Agreement which reveals the type of services rendered by the service provider. The assessee is directed to cooperate in the proceedings before the AO by providing all relevant information. We have placed reliance on Supreme Court judgment in the case of Engineering Analysis Centre of Excellence P. Ltd. [2021 (3) TMI 138 - SUPREME COURT] we have not considered the order of the coordinate Bench of the Tribunal in the case of Urban Ladder Home Décor Solutions Pvt. Ltd.2021 (8) TMI 927 - ITAT BANGALORE]. Appeal is allowed for statistical purposes.
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