9911796707
TMI Blog2023 (12) TMI 717X X X X Extracts X X X X X X X X Extracts X X X X ..... he distribution of the subject channel to cable operators, DTH operators, hotels, etc - HELD THAT:- Tribunal has concluded that the distribution fee could not be construed as royalty and hence was not taxable. Received of distribution fee - whether in the period in issue i.e., AY 2008-09, it had received any distribution fee? - A finding of fact has been returned, which is that in the peri ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Mr Anurag Singhal, Advs. RAJIV SHAKDHER, J. (ORAL): CM APPL. 53746/2023 1. Allowed, subject to just exceptions. CM APPL. 53747/2023 [Application filed on behalf of the appellant/revenue seeking condonation of delay of 05 days in filing the appeal] CM APPL. 53748/2023 [Application filed on behalf of the appellant/revenue seeking condonation of delay of 96 days in r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he order dated 21.11.2022 passed by the Income Tax Appellate Tribunal [in short, Tribunal ]. 9. The Tribunal via the impugned order considered two issues. 9.1 First, whether the revenue earned from distribution rights transferred by the respondent/assessee in favour of BBC Worldwide (India) Pvt. Ltd. [ BWIPL ] concerning the distribution of the subject channel to cable operators, DTH operat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 13. In our view, if one were to take into account the finding of fact returned qua the second issue, clearly, no case for interference with the impugned order is made out by the appellant/revenue. 14. According to us, no substantial question of law arises for our consideration. 15. The appeal is accordingly closed. 16. Parties will act based on the digitally signed copy of the order. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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