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    <title>2020 (6) TMI 264 - ITAT DELHI</title>
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    <description>The Tribunal dismissed the revenue&#039;s appeal and partly allowed the assessee&#039;s appeal. The Tribunal held that the payment for exhibition rights of cinematographic films did not constitute &quot;Royalty&quot; under Section 194J, thus TDS provisions were not applicable. The loan received by the assessee from a company was deemed a commercial advance, not a dividend under Section 2(22)(e). Discrepancies in unexplained investments and cash credits were found unsubstantiated, leading to the deletion of additions. However, unrealized rent, sale of jewellery discrepancies, and unexplained cash deposits were upheld, resulting in the dismissal of those grounds.</description>
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      <title>2020 (6) TMI 264 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=395889</link>
      <description>The Tribunal dismissed the revenue&#039;s appeal and partly allowed the assessee&#039;s appeal. The Tribunal held that the payment for exhibition rights of cinematographic films did not constitute &quot;Royalty&quot; under Section 194J, thus TDS provisions were not applicable. The loan received by the assessee from a company was deemed a commercial advance, not a dividend under Section 2(22)(e). Discrepancies in unexplained investments and cash credits were found unsubstantiated, leading to the deletion of additions. However, unrealized rent, sale of jewellery discrepancies, and unexplained cash deposits were upheld, resulting in the dismissal of those grounds.</description>
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