Play Games 24×7 (P.) Ltd. v. CIT (Appeals) (2026) 348 CTR 103 (Bom.)(HC)

S. 250: Appeal-Commissioner (Appeals)-Procedure-Deduction of tax at source-Writ-Alternate remedy-Assessee to be relegated to the statutory remedy of appeal before the Tribunal-Writ petition against the order of Commissioner (Appeals) was dismissed-Direction that appeals filed within four weeks should be entertained on merits without raising the issue of limitation. [S. 194B, 249, 254(1), Art. 226)

The assessee challenged the order of the Commissioner (Appeals) by a writ petition, contending that section 194B did not require deduction of tax at source on aggregate winnings unless the winnings from an individual game exceeded the prescribed limit. The High Court held that the orders passed by the Commissioner (Appeals) were detailed orders and that an efficacious alternative remedy of appeal before the Tribunal was available. The assessee was, therefore, relegated to the appellate remedy, with a direction that appeals filed within four weeks should be entertained on merits without raising the issue of limitation. (AY. 2015-16, 2017-18 & 2020-21)

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