QUASAR MEDIA PRIVATE LIMITED,NEW DELHI vs. ACIT CIRCLE-20(2), NEW DELHI
Appeal are allowed and the remaining grounds being consequential in nature follow the event
ITA 7088/DEL/2019[2015-16]Status: DisposedITAT Delhi10 Mar 2023AY 2015-16
Bench: Sh. Kul Bharatdr. B. R. R. Kumar
For Appellant: Sh. Anil Bhalla, CAFor Respondent: Sh. Sanjay Kumar, Sr. DR
Section 195Section 40Section 5Section 9(1)Section 9(1)(b)Section 9(1)(i)Section 9(1)(vi)
covered u/s 9(1) as “Royalty”.
6. The AO held that the payments are covered explanation 2
and 5 to section 9(1)(1)(vi). The AO held as under:-
“5. First of all, assessee has himself accepted that NTTA and Dimension have business connection in India
