Fox Network Group Singapore Pte. Ltd. v. ACIT (International Taxation), Circle 1(3)(1), New Delhi 121

TRANS WORLD INTERNATIONAL LLC,WILMINGTON, DELAWARE, USA vs. DEPUTY COMMISSIONER OF INCOME TA, CIRCLE 3(1)(1), INTERNATIONAL TAXATION, CIVIC CENTRE, NEAR MINTO ROAD, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘D’: NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER ITA Nos.1960, 1961 and 2146/DEL/2024 [Assessment Years: 2013-14, 2014-15 and 2015-16] TRANS WORLD Deputy Commissioner of Income Tax INTRNATIONAL LLC, Circle (International Taxation)-3(1)(1) C/o- International Vs E-2 Block, Civic Centre, Merchandising Company LLC- Near Minto Road, India Branch Office, Vatika New Delhi-110002 Business Centre 2nd Floor, Business Suites No.24 & 25, First India Place, Sushant Lok-1, Phase-1, Block –B, Mehrauli Gurgaon Road, Harya…

TRANS WORLD INTERNATIONAL LLC,WILMINGTON, DELAWARE, USA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(1)(1), INTERNATIONAL TAXATION, NEW DELHI

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘D’: NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER ITA Nos.1960, 1961 and 2146/DEL/2024 [Assessment Years: 2013-14, 2014-15 and 2015-16] | Appellant | |---|---| | TRANS WORLD INTRNATIONAL LLC, C/o- International Merchandising Company LLC- India Branch Office, Vatika Business Centre 2nd Floor, Business Suites No.24 & 25, First India Place, Sushant Lok-1, Phase-1, Block –B, Mehrauli Gurgaon Road, Haryana-122002 PAN-AAGCT0812L | Vs | Deputy Commissioner of Income Tax Circle (International Taxation)-3(1)(1) E-2 B…

CRICKET AUSTRALIA,MUMBAI vs. ACIT CIRCLE 1(2)(1) INTL. TAXATION , NEW DELHI

Bench: SHRI G.S. PANNU, HON'BLE (Vice President), SHRI ANUBHAV SHARMA (Judicial Member)

…oordinate Bench in AY 2018-19 (supra), it comes up that the Coordinate Bench had relied another Coordinate Bench order dated 20.3.2020 in the case of Fox Network Group Singapore Pte. Ltd. vs. ACIT (International Taxation), Circle 1(3)(1), New Delhi 121 (2020) 121 Taxmann.com 330 (Delhi Tribunal) to benefit the assessee holding that the 5 fee received towards live transmission cannot be taxed as royalty. This decision of the Delhi Tribunal has been affirmed by the Hon’ble Delhi High Court in the case of CIT vs. Fox Network Group Singapore Pte. Ltd. (2024) 158 taxmann.com 434. In light of the aforesaid, we are incl…

LEX SPORTEL VISION PRIVATE LIMITED,NEW DELHI vs. ITO,WARD INT. TAXATION 2(2)(1), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘D’, NEW DELHI Before Sh. Saktijit Dey, Vice President Dr. B. R. R. Kumar, Accountant Member ITA No. 2397/Del/2023 : Asstt. Year: 2018-19 Lex Sportel Vision Pvt. Ltd., Vs Income Tax Officer, D-583, Basement Chittaranjan Ward, Intl. Taxation-2(2)(1), Park, New Delhi New Delhi-110002 (APPELLANT) (RESPONDENT) PAN No. AACCL7867K Assessee by : Sh. Ajay Vohra, Sr. Adv. Revenue by : Sh. Sanjay Kumar, Sr. DR Date of Hearing: 09.10.2023 Date of Pronouncement: 26.12.2023 ORDER Per Dr. B. R. R. Kumar, Accountant Member: The present appeal has been filed by assessee against t…

CRICKET AUSTRALIA,AUSTRALIA vs. ACIT (INTERNATIONAL TAXATION),CIRCLE-1(2)(1), DELHI

In the result, the appeal of the assessee is partly allowed

Bench: Shri Kul Bharat & Shri M.Balaganesh[Assessment Year : 2018-19] Cricket Australia, Vs Acit (International No.60, Jolimant Street, Jolimont Taxation), Victoria, Australia-3002. Circle-1(2)(1), Pan-Aaecc5341D Delhi. Appellant Respondent Appellant By Shri Percy Pardiwala, Sr.Adv. & Shri Nitesh Joshi, Adv. Respondent By Shri Vizay B.Vasanta, Cit Dr Date Of Hearing 06.06.2023 Date Of Pronouncement 24.08.2023 Order Per Kul Bharat, Jm : The Present Appeal Filed By The Assessee For The Assessment Year 2018- 19 Is Directed Against The Assessment Order Passed U/S 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 (“The Act”) Dated 27.03.2022. 2. The Assessee Has Raised Following Grounds Of Appeal:-

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI “D” BENCH: NEW DELHI BEFORE SHRI KUL BHARAT, JUDICIAL MEMBER & SHRI M.BALAGANESH, ACCOUNTANT MEMBER [Assessment Year : 2018-19] Cricket Australia, vs ACIT (International No.60, Jolimant Street, Jolimont Taxation), Victoria, Australia-3002. Circle-1(2)(1), PAN-AAECC5341D Delhi. APPELLANT RESPONDENT Appellant by Shri Percy Pardiwala, Sr.Adv. & Shri Nitesh Joshi, Adv. Respondent by Shri Vizay B.Vasanta, CIT DR Date of Hearing 06.06.2023 Date of Pronouncement 24.08.2023 ORDER PER KUL BHARAT, JM : The present appeal filed by the assessee for the assessment year 2018- 19 is d…

ESS (FORMERLY KNWON AS ESPN STAR SPORTS),MUMBAI vs. ACIT, CIRCLE- 1(2)(2), INTERNATIONAL TAXTION, NEW DELHI

Appeal of the assessee is partly allowed

Bench: Shri Narendra Kumar Billaiya & Shri Kul Bharat

…1 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “D”: NEW DELHI BEFORE SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER AND SHRI KUL BHARAT, JUDICIAL MEMBER ITA No. _7903/DEL/2018 [Assessment Year: 2014-15 ESS (Formerly known as Vs ACIT, Circle-1(2)(2), ESPN Star Sports), International Taxation, C/o Star India Pvt. Ltd., New Delhi. Star House, Urmi Estate, 95, Ganpatrao Kadam Marg, Lower Parel West, Mumbai-400013 PAN- AABCE0838N APPELLANT RESPONDENT Sh. Porus Kaka, Sr. Adv. Assessee represented by Department represented by Sh. Gangadhar Panda, CIT-DR Date of hearing 15.12.2022 Date of pronouncement 21.02.2023…