9911796707
TMI Blog2019 (4) TMI 1421X X X X Extracts X X X X X X X X Extracts X X X X ..... on under section 194J of the Act has come up for consideration in assessee s own case [ 2016 (1) TMI 213 - ITAT MUMBAI] The Tribunal while deciding the issue in unequivocal terms has held that the payment made towards carriage fees / channel placement fees does not partake the character of either royalty or fees for technical services. Thus, the issue having been decided in favour of the asses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sessee a company is in the business of broadcasting of business news. For the assessment year under dispute, the assessee filed its return of income on 29th May 2010, declaring loss of ₹ 80,28,81,877, under normal provisions. During the assessment proceedings, the Assessing Officer noticed that the assessee has debited an amount of ₹ 31,71,14,238, to the Profit Loss account on accoun ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... king note of the fact that following the decision of the Tribunal in assessee s own case the First Appellate Authority has deleted similar disallowance made under section 40(a)(ia) of the Act in assessment year 2011 12 and 2012 13, followed the same and deleted the disallowance in the impugned assessment year as well. 4. We have heard learned Counsels appearing for the parties and p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the provisions of section 194J of the Act are not applicable. He submitted, while considering identical nature of dispute relating to disallowance made under section 40(a)(ia) of the Act in assessee s own case for assessment year 2011 12 and 2012 13 in ITA no.3689 and 3690/Mum./2017, dated 15th October 2017, the Tribunal has deleted the disallowance by holding that provisions of section 194J of th ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
