Tata Sky Ltd. v. ACIT (2020) 195 DTR 177 / 208 TTJ 194 (Mum.)(Trib.)

S. 40(a)(ia) : Amounts not deductible-Deduction at source-TDS to be deducted on payment for sale promotion, legal and professional fees, etc.-Even if it was not credited to the respective parties account-Disallowance is confirmed. [S. 201(1), 201(IA)]

TDS on the year end provisions in respect of expenditures on account of sale promotion, legal and professional fees, internet and programming costs and further debited these provisions to its profit and loss account, was to be deducted on such expenditures even if the same was not credited to the respective parties account.  (AY. 2009-10, 2010-11)