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Appellant, a Singapore tax resident company engaged in broadcasting television programs, challenged tax liability on advertisement revenues in India. ITAT held that following principle of tax certainty and consistency, appellant's revenue should be taxed as per Mutual Agreement Procedure (MAP) resolution for impugned AY 2013-14, similar to earlier and subsequent years, since there was no change in factual matrix and business operations: 10% of gross advertising revenues taxable @40%, net distribution revenues taxable @10% plus surcharge and cess. Regarding penalty u/s 271(1)(c), ITAT found no inaccurate income particulars furnished by appellant who disclosed complete facts and offered bona fide explanation based on judicial precedents. No penalty imposable given recent MAP resolution without mentioning penalty.
Appellant, a Singapore tax resident company engaged in broadcasting television programs, challenged tax liability on advertisement revenues in India. ITAT held that following principle of tax certainty and consistency, appellant's revenue should be taxed as per Mutual Agreement Procedure (MAP) resolution for impugned AY 2013-14, similar to earlier and subsequent years, since there was no change in factual matrix and business operations: 10% of gross advertising revenues taxable @40%, net distribution revenues taxable @10% plus surcharge and cess. Regarding penalty u/s 271(1)(c), ITAT found no inaccurate income particulars furnished by appellant who disclosed complete facts and offered bona fide explanation based on judicial precedents. No penalty imposable given recent MAP resolution without mentioning penalty.
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