Dismissing the appeal of the revenue the Tribunal held that transponder charges were not in nature of royalty in hands of recipient despite amendment to section 9(1)(vi) and, therefore, there was no liability on part of assessee to deduct TDS on payments. Followed PCIT v. NEO Sports Broadcast (2019) 107 taxmann.com 17 (Bom.)(HC) (AY. 2015-16, 2016-17, 2020-21)
ACIT (IT) v. Viacom18 Media (P.) Ltd. (2022) 193 ITD 716 (Mum.) (Trib.)
S. 195 : Deduction at source-Non-resident-Transponder service fee-Not in nature of royalty in hand of recipient-Not liable to deduct tax at source. [S. 9(1)(vii), 195(2)]