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TMI Blog2024 (3) TMI 1349X X X X Extracts X X X X X X X X Extracts X X X X ..... tice Purushaindra Kumar For the Respondent : Mr. Rohan Khare and Ms. Priyam Bhatnagar, Advocates. For the Respondent : Mr. Rohan Khare and Ms. Priyam Bhatnagar, Advocates. ORDER 1. The Revenue has instituted the instant appeals and has proposed the following questions of law for our consideration:- "2.1 Whether on the facts and in the circumstances of the case, the ld. ITAT has erred in hold ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ted hereinbelow:- "2. Issue notice. 2.1 Mr Deepak Chopra accepts notice on behalf of the respondent/assessee. 3. We may note, that it is Mr Chopra's contention, that apart from anything else, the issue which arises for consideration in the instant case, i.e., as to whether the revenue received on account of advertising and distribution rights should be treated as royalty, is inter alia ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2008-2009. 6.1 Mr Chopra says, that the assessment orders, insofar as these assessment years were concerned, were passed under Section 143(3) of the Income Tax Act, 1961 [in short "Act"]. 7. Insofar as the above-captioned matters are concerned, we are told by learned counsel for the parties, that they relate to AYs 2009- 2010, 2010-2011, 2011-2012, 2012-2013, 2013-2014 and 2015- 2016. 8. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sessee having agreed to pay 10% of advertising and subscription revenue is not disputed. As would be manifest from a reading of paragraph nos. 4 to 6 of our order dated 14 December 2022, the aforesaid practice is also stated to have been accepted by the Revenue for Assessment Years 2007-08 and 2008-09. 4. In view of the aforesaid and bearing in mind the principles of consistency, we find no justi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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