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2014 (5) TMI 327

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....rder of the Tribunal on other pending cases. He submits that if the present Appeal is considered by this Court in the backdrop of the facts and circumstances peculiar to it, the order passed by this Court may affect large number of cases and proceedings in which similar issue may be involved. 3. First of all, we do not appreciate such requests because the matters are notified for admission well in advance. We expect counsel appearing for the Revenue and the assessee, both to be ready with the arguments so that the Court's time is not wasted. Secondly, in the view that we are taking and based on the facts peculiar to the case of the present assessee, we do not think that our order of such nature can have any impact on pending cases as a....

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....ry, inter alia, and as defined referred to, and included India. 6. The proceedings were initiated so as to bring the payment within the tax law and namely, the Income Tax Act, 1961. The allegation was that the tax was not deducted at source from the payments made to Global Cricket Corporation. 7. Both the Commissioner of Income Tax (Appeals) as also the Tribunal held that if the underlying facts noted by us hereinabove are not in dispute, then, the payment for the cricket rights is made only for broadcasting operations of the assessee which are carried out from Singapore. The liability for the payment is incurred by the assessee in connection with the broadcasting operations in Singapore. That has no connection with the marketing activiti....