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Petitioner's revenue from an Indian payer was not subjected to tax deduction at source, despite being taxable income in India. The assessing officer reopened assessment u/s 147, contending the live feed component was taxable as royalty and rejecting the 95:5 bifurcation of license fee between live feed and recorded content. Following the Delhi High Court's decision in CIT v. Fox Network Group, the court found no justification for the reassessment action. The assessing officer's view rejecting the 95:5 bifurcation was rendered perverse in light of the agreement's stipulations. Consequently, the court allowed the writ petitions and quashed the order u/s 148A(d).
Petitioner's revenue from an Indian payer was not subjected to tax deduction at source, despite being taxable income in India. The assessing officer reopened assessment u/s 147, contending the live feed component was taxable as royalty and rejecting the 95:5 bifurcation of license fee between live feed and recorded content. Following the Delhi High Court's decision in CIT v. Fox Network Group, the court found no justification for the reassessment action. The assessing officer's view rejecting the 95:5 bifurcation was rendered perverse in light of the agreement's stipulations. Consequently, the court allowed the writ petitions and quashed the order u/s 148A(d).
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