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TMI Blog2015 (10) TMI 2797X X X X Extracts X X X X X X X X Extracts X X X X ..... - ITAT CHENNAI] wherein held we are not in a position to express any opinion whether the assessee is having any element of income from subscription charges received from various parties. Therefore, if the entire subscription received by the assessee is transferred to M/s. Sun TV and the assessee is entitled only for commission on subscription income, then the Tribunal s decision relied by the ass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f Income-tax(Appeals) dated 2.3.2015. 2. The Revenue has raised the following grounds: 2.1 The learned CIT(A) erred in deleting the disallowance made by the AO u/s.199 in view of 1 st and 2nd proviso to the tune of ₹ 2,62,70,314/- on claim for TDS credit. 2.2 The learned CIT(A) ought to have appreciated the fact that Credit for Tax Deducted at Source can be given only to the exten ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... behalf of M/s.TV Net work and demanding ₹ 1,98,10,730/-. Aggrieved, the assessee went in appeal before the Commissioner of Income-tax(Appeals), who following the decision of the Tribunal in assessee s own case in ITA No.884/Mds/2011 dated 21.10.2013 for the assessment year 2006-07, allowed the ground of appeal. Against this, the Revenue is in appeal before us. 4. We have heard both the p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee s counsel filed only financial statement and not filed ledger accounts of subscription received account. 6. Hence, we are not in a position to express any opinion whether the assessee is having any element of income from subscription charges received from various parties. Therefore, if the entire subscription received by the assessee is transferred to M/s. Sun TV and the assessee is e ..... X X X X Extracts X X X X X X X X Extracts X X X X
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