BBC GLOBAL NEWS INDIA PRIVATE LIMITED,NEW DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

ITA 4460/DEL/2024Status: DisposedITAT Delhi21 August 2026AY 2020-2118 pages
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What were the facts?

The assessee, BBC Global News India Private Limited, appealed an assessment order concerning AY 2020-21. The appeal involved transfer pricing issues related to reimbursement of expenses and license fees, as well as corporate tax grounds concerning foreign tax deductions and interest levies.

What did the Tribunal hold?

The Tribunal held that the issue of license fee benchmarking should be remitted back to the AO/TPO to consider additional comparables under the CUP method. The claim for deduction of foreign taxes paid outside India was also allowed for statistical purposes, directing the AO to verify the claim.

What were the issues?

Whether reimbursement of expenses received by the assessee are subject to a mark-up, and whether foreign taxes not eligible for credit under Section 90/91 can be claimed as a deduction under Section 37.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13),Section 37,Section 90,Section 91,Section 234D,Section 244A,Section 271AA

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH ‘H’: NEW DELHI

For Appellant: Shri Sachit Jolly, Sr. Advocate, Shri Sohum Dua, Advocate, Shri Sandeep Bhalla, CA, Shri Ashish Agrawal, CA, Shri Anurag Singhal, CA, Shri Rahul Mehta, CA
For Respondent: Shri Bhopal Singh, CIT DR
Hearing: 01.06.2026Pronounced: 21.08.2026

PER S.RIFAURRAHMAN,AM:

1.

This appeal filed by the assessee is directed against the assessment order dated 31.07.2024 passed by the ACIT, Central Circle 8, Delhi under section 143(3) read with section 144(C)(13) of the Income-tax Act, 1961 (for short ‘the Act”) for Assessment Year 2020-21 pursuant to the directions of the Dispute Resolution Panel u/s 144C (5) of the Act raising

2 the following grounds of appeal :- “1. On the facts and in the circumstances of the case and in law, the assessment order dated 31 July 2024 passed by the Ld. AO under section 1

The order continues below.

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