TaxTMI 
TaxTMI 
2019 (1) TMI 806
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....r. Atul Jasani for the respondent P.C. 1. The Revenue has filed both the appeals against the common judgment of the Income Tax Appellate Tribunal, raising similar question of law for our consideration, which is as under :( i) Whether on the facts and in the circumstances of the case and in law, the Tribunal is correct in holding that the placement fees / carriage fees paid to cable operat....
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....the CIT(A), has placed reliance on the decision of the Tribunal in the case of UTV Entertainment Television. We notice that such decision of the Tribunal was carried in appeal by the Department in Income Tax Appeal No.525 of 2015 and connected appeals. These appeals were dismissed by an order dated 10/11th October, 2017. The Court in the said judgment has made following observations : "14. The Co....
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....J is to be applied, the deduction would be of 10%. The Commissioner (Appeals) has also gone through the method followed by the cable operators/ MSOs. The Commissioner (Appeals) has also gone into the submission of the Revenue that, in fact, Section 194J would apply. In substance, the argument is that placement charges are basically for rendering technical service. The Commissioner (Appeals) has r....
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....telecasting the channels of the respondent, the same would be covered by Section 194C as it falls in clause (iv) of the definition of "work". Therefore, when placement charges are paid by the respondent to the cable operators/ MSOs for placing the signals on a preferred band, it is a part of work of broadcasting and telecasting covered by sub-clause (b) of clause (iv) of the explanation to Section....