2023 (7) TMI 1156

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....71(1)(c) vide order dated 29/03/2017 passed by the DCIT, Cent.Cir.4(2). 3. The assessee is a 100% subsidiary of Red Chillies Entertainment Pvt. Ltd. The objects of the assessee company amongst others, includes setting up, buying, selling, acquiring, managing, running, operating on outright or in joint-venture or under franchisee or in partnership or under any kind of contract or arrangement for sharing of profits of sports team and sport players, setting up, managing and operating sports academy, promoting developing and managing sports talent, etc. The assessee filed the return of income for A.Y. 2011-12 on 28/09/2011 declaring a total loss of Rs. 11,04,28,232/-. The return for A.Y. 2012-13 was filed on 28/09/2012 declaring total income....

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....Aggrieved, the Revenue is in appeal before the Tribunal. 5. The Ld.DR submitted that the department is in appeal before the High Court against the relief given by the Tribunal in the quantum appeal. The Ld.DR further submitted that there are contrary views taken by different benches of the Tribunal regarding the treatment of Franchise Fees and reference under section 255(3) for constitution of Special Bench is made before Hon'ble President in the matter of Role Model Support Pvt Ltd vs ACIT in ITA No.3602/Mum/2014. Therefore, it is contended by the ld DR that issues in the quantum appeal have not reached finality and that the penalty proceedings should be kept alive accordingly. 6. The Ld.AR, on the other hand, submitted that the co-o....