Allowing the petition the Court held that clause D of the agreement between the assessee and the Indian entity, for the grant of telecast of matches, bifurcated the licence fee between live feed and recorded content. The view of the Assessing Officer that there was no basis for the bifurcation of the receipt in the ratio of 95 per cent. and five per cent. was perverse in view of the stipulations contained in the agreement. No contestation existed on the issue of taxability of live feed. There was no justification to recognize a right inhering in the Revenue to continue the reassessment proceedings under section 147. The initial notice issued under section 148A(b), the order passed under section 148A(d) and the notice issued under section 148 were quashed.(AY. 2016-17, 2017-18, 2018-19)