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2015 (1) TMI 1422 - ITAT MUMBAITDS u/s 194C or 194J - payment made to cable operators/DTH operators for channel placement - assessee is engaged in the business of distribution of television channels - CIT(A) held that the payment for placement of channel falls u/s 194C for the purpose of deduction of tax and not u/s 194J - HELD THAT:- The issue is covered in favour of the assessee by the decisions of this Tribunal in the case of ACIT Vs. UTV Entertainment Television Ltd. [2014 (12) TMI 716 - ITAT MUMBAI] and ACIT Vs. M/s. NGC Networks (I) Pvt. Ltd. [2014 (11) TMI 484 - ITAT MUMBAI] wherein the Tribunal has held that the fee for placement of channel does not fall u/s 194J but the same falls u/s 194C. Hence the CIT(A) has rightly held that the TDS in respect of the payment has to be deducted u/s 194C. TDS u/s 194J or 194C in respect of dubbing charges - HELD THAT:- Identical issue was considered and decided by this Tribunal in the case of ACIT Vs. Manish Dutt [2012 (7) TMI 186 - ITAT MUMBAI] wherein it was held that the payment made for dubbing work falls under section 194C and not u/s 194I. The Tribunal again in case of UTV Entertainment Television Limited [2014 (12) TMI 716 - ITAT MUMBAI] had decided a similar issue as held that assessee had thus carried out the work of dubbing by engaging services and the same was of the nature of getting work done through a sub-contractor. The findings of the CIT(A) in this regard are not in challenge before us. In such circumstances we are of the view that the provisions of section 194C were applicable
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