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2023 (12) TMI 717 - HC - Income TaxIncome taxable in India - revenue earned from distribution rights transferred by assessee in favour of BBC Worldwide (India) Pvt. Ltd. [“BWIPL”] concerning the distribution of the subject channel to cable operators, DTH operators, hotels, etc - HELD THAT:- Tribunal has concluded that the distribution fee could not be construed as royalty and hence was not taxable. Received of distribution fee - whether in the period in issue i.e., AY 2008-09, it had received any distribution fee? - A finding of fact has been returned, which is that in the period in issue i.e., AY 2008-09, the assessee did not receive any distribution fee and therefore, no profit could be attributed to it. In our view, if one were to take into account the finding of fact returned qua the second issue, clearly, no case for interference with the impugned order is made out by the appellant/revenue. No substantial question of law arises for our consideration.
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