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    <title>2026 (7) TMI 956 - ITAT MUMBAI</title>
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    <description>For AY 2017-18, the withholding threshold for card-game and other gaming winnings applies to each payment when made, rather than to cumulative wallet balances or winnings accrued during the financial year. The unamended provision contained no aggregation requirement, unlike provisions that expressly require aggregation. Disallowance for withholding non-compliance does not apply to player payouts that were recorded as liabilities, were not debited to the profit and loss account, and were not claimed as deductible expenditure. Payments for Facebook banner advertisements are characterised as consideration for a standard platform facility, not royalty or fees for technical services, where the payer receives no rights in servers, dedicated equipment, or technical or consultancy services.</description>
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