The question before the High Court was “Whether on the facts and in the circumstances of the case and in law, the Tribunal was right in holding that the placement fees/carriage fees paid to cable operators/MSO/DTH Operators are payments for work contract covered u/s 194C and not fees for technical service u/s 194J, without appreciating that the service received by the assessee are technical in nature? . Following the order in CIT v. UTV Entertainment Television Ltd (2017) 399 ITR 443 (Bom)(HC), decided in favour of the assessee. (Arising out of ITA No.669/Mum/2012 dt.17/03/2015)(ITA No. 399 of 2016 dt.14/08/2018) (AY 2008 – 2009 , 2009 – 2010)
CIT v. Times Global Broadcasting Co. Ltd. (2019)105 taxman .com 313 / 263 Taxman 466(Bom)(HC) Editorial: SLP of revenue is dismissed, CIT v. Times Global Broadcasting Co. Ltd. (2019) 263 Taxman 465 (SC)/ (SLP No.6242 of 2019)(2019) 412 ITR 41 (St.)(SC)
S. 194C : Deduction at source – Contractors -Placement fees/carriage fees – work contract and not fees for technical service [ S.194J ]