DCIT, MUMBAI vs. PLAY GAMES 24X7 PRIVATE LIMITED , MUMBAI

ITA 7074/MUM/2025Status: DisposedITAT Mumbai25 September 2026AY 2015-1623 pages
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What were the facts?

The assessee, engaged in online gaming, faced disallowances for alleged non-deduction of TDS on winnings and promotional expenditure. The Revenue appealed against the deletion of these disallowances and a deduction claimed under Section 80G and ESOP expenditure.

What did the Tribunal hold?

The Tribunal held that TDS under Section 194B was not required on winnings aggregated over the financial year, but only on individual payments exceeding the threshold. It also upheld the deletion of disallowances related to CSR expenditure (Section 80G) and ESOPs, finding them eligible for deduction.

What were the issues?

Whether TDS under Section 194B is applicable on aggregated winnings or individual payments, and whether CSR expenditure is eligible for deduction under Section 80G.

Which sections of the Income-tax Act were involved?

Section 40(a)(ia),Section 194B,Section 80G,Section 37(1),Section 135,Section 263,Section 143(3),Section 254

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Heard together (4 matters)

ITA 7074/MUM/2025
ITA 7077/MUM/2025
ITA 8300/MUM/2025
ITA 8301/MUM/2025

Read from the judgment's own cause title. This page is filed under one of them.

आयकर अपील"य अ"धकरण, मुंबई पीठ", मुंबई INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCHES, MUMBAI BENCH: C BEFORE SMT. BEENA PILLAI, HON’BLE JUDICIAL MEMBER AND SHRI JAGADISH, HON’BLE ACCOUNTANT MEMBER ITA 7074/MUM/2025 (िनधा"रण वष"/Assessment Year: 2015-16) DCIT PLAY GAMES 24X7 PRIVATE LIMITED 218, 2ND FLOOR, AAYKAR BHAVAN, MUMBAI-400020, 5TH, FLOOR, CENTRAL (B) MUMBAI-400063, MAHARASHTRA अपीलाथ" Appellant ""थ" Respondent

PAN of Assessee: AADCP9139P

अपीलाथ" "ारा/Appellant represented Shri Rajdeep Singh CIT-DR by: Shri Rohan Shah, senor counsel a/w Mr. Mohammed ""थ" "ारा/Respondent represented anajwalla, Adv (Instructed by by: M/s MSKA & Associates LLP CA's)

ITA 7077/MUM/2025 (िनधा"रण वष"/Assessment Year: 2020-21) DCIT, CIRCLE-13(1)(2), PLAY GAMES 24X7 MUMBAI PRIVATE LIMITED ROOM NO. 218, 2ND FLOOR, GOREGAON (E) Vs. AAYKAR BHAVAN, MUMBAI- MUMBAI-400063, 400020, MAHARASHTRA MAHARASHTRA अपीलाथ" Appellant ""थ" Respondent

PAN of Assessee: AADCP9139P

अपीलाथ" "ारा/Appellant represented Shri Rajdeep Singh CIT-DR by:

ITA 7074/MUM/2025 ITA 7077/MUM/2025 ITA 8300/MUM/2025 ITA 8301/MUM/2025 PLAY GAMES 24X7 PRIV

The order continues below.

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