2016 (1) TMI 1368

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....I.TA No. 1553/Mum/2015 - -<br>Income Tax<br>Shri N.K. Billaiya, Accountant Member And &nbsp;Shri C.N. Prasad, Judicial Member Department by: Shri Jasbir Chauhan Assesee by: Shri Porus Kaka Shri Divesh Chawla ORDER Per N.K. Billaiya, AM: These appeals by the Revenue and cross objections by the assessee are directed against the orders of the DRP-IV, Mumbai in case of two different ass....

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.... the very outset, the Ld. Counsel for the assessee stated that the issues in appeal have been decided in favour of the assessee and against the Revenue in assessee's own case for A.Y. 2009-10 in ITA No. 1382/M/2014 and C.O. No. 68/M/14 and also in the case of M/s. Star Den Media Services Pvt. Ltd in ITA No. 1413/M/14 with C.O. No. 71/M/14 and ITA No. 1414/M/14 with C.O. No. 72/M/14. The Ld. Counse....

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....i) of the Act. &nbsp; 6. We have given a thoughtful consideration to the rival submissions. We have also gone through the orders of the authorities below and the decisions of the Tribunal relied upon by the Ld. Counsel and brought to our notice. &nbsp; 6.1. At the very outset we have to say that the contention of the Ld. DR to refer the matter to the Special Bench is ill founded. The decisio....

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.... Co ordinate Bench also strengthens our view that the reliance placed by the Ld. DR on the decision of Viacom 18 Media Pvt. Ltd. 162 TTJ 336 is misplaced. In our considered opinion, there is no conflict in the decision of NGC Network (I) Pvt. Ltd 150 ITD 772 and Viacom 18 Media Pvt. Ltd. 162 TTJ 336 since both the decisions relate to different set of facts and payments are for different purposes. ....