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TMI Blog2019 (4) TMI 2070X X X X Extracts X X X X X X X X Extracts X X X X ..... ibunal held that such amount cannot be added separately because it had been already included in the pool and in the combined rate of 27.18% (PSM), therefore retaining this amount would amount to double taxation - HELD THAT:- We gather that the Tribunal is correct is making the above observations. We notice that there is no dispute about the quantification of 50% of total distribution. The assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tain the Appeal. - INCOME TAX APPEAL NO. 200 OF 2017 - - - Dated:- 30-4-2019 - AKIL KURESHI AND SARANG V. KOTWAL, JJ. For the Appellant : Mr.Tejveer Singh, Advocate. For the Respondent : Mr.Porus Kaka, Senior Advocate with Mr.Divesh Chawla i/b. Mr.Atul Jasani, Advocate ORDER P.C.: 1. This Appeal is filed by the revenue to challenge the judgment of Income Tax Appella ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s a registered company engaged in business of television distribution of channels. The appeal relates to the return of income tax for the assessment year 20072008. The question (a) relates to computation of distribution revenue of which a certain proportion would be accrued as the income. The Tribunal in the impugned judgment noted that this distribution revenue has been taxed in the hands of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... therefore arises. 4. Second question pertains to whether the Petitioner is liable to pay interest under section 234B of the Income Tax Act, 1961, on non deduction of tax at source. The assessee being the payee, relies on the decision of this Court in case of Director of Income Tax (international Taxation) Vs. NGC Network Asia LLC, reported in 313 ITR 187 (Bom). Apart from the said judgment, we ..... X X X X Extracts X X X X X X X X Extracts X X X X
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