ADIT CIR 2(2), MUMBAI vs. TAJ TV LTD, MUMBAI
In the result, the appeals of the assessee are allowed and that of the Revenue are dismissed
ITA 2073/MUM/2012[2007-08]Status: DisposedITAT Mumbai23 Dec 2016AY 2007-08
Bench: Sri Amit Shukla,Jm & Sri Ashwani Taneja,Am
Section 143(3)Section 144CSection 195Section 40Section 9Section 9(1)
…he judgment of the Hon'ble Supreme Court in Morgan Stanley & Co. and the principle therein would apply. Similarly, the Division Bench judgment of this Court in the case of Set Satellite (Singapore) Pte Ltd. vs. Deputy Director of Income Tax (IT) & Anr. (2008) 307 ITR 265 would conclude this aspect. Therefore, we are of the opinion that the Tribunal's conclusions and which are consistent with the factual materials and the principles of law laid down above are neither perverse nor vitiated by any error of law apparent on the face of the record.” Thus, if admittedly Taj India is being remunerated at arm‟s length, th…