2006 (8) TMI 114

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....ITA No.4716/Del/2004 relevant for the assessment year 1989-90. 2. The Assessee had claimed a deduction under Section 80 HHC of the Income-Tax Act in respect of dubbing rights of Hindi films, which it says, it had sold to some foreign company. The Assessing Officer did not agree that it was a sale by the Assessee and concluded that it was not a sale of goods or merchandise but a receipt of royalty....

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....he Revenue is before us. 6. Having examined the record and heard learned counsel for the Revenue, we are of the opinion that there is nothing to suggest that the Assessee was in any manner trying to mislead the Assessing Officer. It appears that he had a bona fide belief that by selling dubbing rights to foreign company, he was selling goods or merchandise within the meaning of Section 80 HHC of ....