2022 (11) TMI 1315

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.... Advocate Sh. Ankit Sahani, Advocate. For the Respondent : Sh. Gangadhar Panda, CIT (DR. ORDER PER SAKTIJIT DEY, JM : The assessee has filed the present appeal challenging the final assessment order dated 19.04.2021 passed under section 143(3) read with section 144C(13) of the Income-tax Act, 1961 (in short 'the Act') pertaining to assessment year 2017-18, in pursuance to the direction....

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....partmental authorities, the assessee derives its income by providing Satellite Transmission Services to its customers worldwide. The satellites of the assessee are located in the Geostationary Orbit of the Earth. For provision of Satellite Transmission Services, the assessee entered into an agreement with broadcasting companies having TV Channels and communication companies. Broadcasting/communica....

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....er by treating the receipts of the assessee from Satellite Transmission Services as royalty and accordingly determined the total income at Rs.88,03,86,325/-. Against the draft assessment order so passed, the assessee raised objection before learned DRP. However, learned DRP did not interfere with the decision of the Assessing Officer. 3. Before us, learned counsel appearing for the assessee sub....

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.... case in preceding assessment years beginning from assessment year 2006-07 onwards, they have concluded that the receipts of the assessee from Satellite Transmission Services are in the nature of royalty. However, it is a fact on record that disputing the decision of the departmental authorities' assessee carried appeals to the Tribunal in preceding assessment years. While deciding the issue, the ....