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    <title>2019 (1) TMI 2086 - ITAT MUMBAI</title>
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    <description>Payments for carriage fees, channel placement fees, uplinking charges and bandwidth charges used for broadcasting were treated as contractual charges for transmission and broadcasting facilities, not as fees for technical services or royalty. On that basis, tax was deductible under section 194C and not under section 194J. The Tribunal also held that the retrospective widening of the word &quot;process&quot; in Explanation 6 to section 9(1)(vi) did not, for the relevant period, justify disallowance under section 40(a)(ia) where tax had been deducted. The Revenue&#039;s challenge failed, and the addition for alleged short deduction was not sustained.</description>
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      <title>2019 (1) TMI 2086 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=468318</link>
      <description>Payments for carriage fees, channel placement fees, uplinking charges and bandwidth charges used for broadcasting were treated as contractual charges for transmission and broadcasting facilities, not as fees for technical services or royalty. On that basis, tax was deductible under section 194C and not under section 194J. The Tribunal also held that the retrospective widening of the word &quot;process&quot; in Explanation 6 to section 9(1)(vi) did not, for the relevant period, justify disallowance under section 40(a)(ia) where tax had been deducted. The Revenue&#039;s challenge failed, and the addition for alleged short deduction was not sustained.</description>
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