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    <title>2014 (6) TMI 410 - ITAT COCHIN</title>
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    <description>The Tribunal ruled in favor of the assessee, directing deletion of the disallowance of pay channel charges under sec. 40(a)(ia) for failure to deduct tax at source, as the charges were not considered as royalty subject to TDS. The decision was based on the interpretation of &quot;royalty&quot; under Explanation 2 to sec. 9(1) and the clarification added by Explanation 6 through the Finance Act, 2012. The Tribunal held that the amendments did not impose TDS liability on the pay channel charges, in line with the Asia Satellite Telecommunications Co. Ltd. case.</description>
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      <title>2014 (6) TMI 410 - ITAT COCHIN</title>
      <link>https://www.taxtmi.com/caselaws?id=248506</link>
      <description>The Tribunal ruled in favor of the assessee, directing deletion of the disallowance of pay channel charges under sec. 40(a)(ia) for failure to deduct tax at source, as the charges were not considered as royalty subject to TDS. The decision was based on the interpretation of &quot;royalty&quot; under Explanation 2 to sec. 9(1) and the clarification added by Explanation 6 through the Finance Act, 2012. The Tribunal held that the amendments did not impose TDS liability on the pay channel charges, in line with the Asia Satellite Telecommunications Co. Ltd. case.</description>
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