ASIA TODAY LTD,MUMBAI vs. ADIT (IT) 2(2), MUMBAI
In the result, Assessee's appeal is allowed
ITA 1403/MUM/2008[2004-2005]Status: DisposedITAT Mumbai24 Dec 2025AY 2004-2005
Bench: Shri Narender Kumar Choudhry & Shri Omkareshwar Chidaraassessment Year: 2004-05 M/S. Asia Today Limited, Asst. Director Of Income C/O. Zee Entertainment Enterprises Tax (International Ltd., Vs. Taxation)-2(2), 135, Dr. Annie Besant Road, Scindia House, Worli, Mumbai – 400 018 Bellard Estate, Pan: Aabca0249F Mumbai - 400039 (Appellant) (Respondent) Present For: Assessee By : Shri Niraj Sheth, Ld. A.R. Revenue By : Shri Krishna Kumar, Ld. Sr. D.R. Date Of Hearing : 10.10.2025 Date Of Pronouncement : 24.12.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 25.01.2007, Impugned Herein, Passed By The Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2004-05. 2. The Relevant Facts For Adjudication Of This Appeal Are As Under: The Assessee, Being A Foreign Telecasting Company Incorporated In Mauritius & Having Tax Residency Certificate Of Mauritius , During The Ay Under Consideration Was Engaged In The Production & Acquiring Rights Of Various Television Films Including Feature Films, As A Copy Right Owner/Holder Of Various Hindi Feature Films Produced & Censored In India, As Mentioned In Schedule ‘C’ Annexed With The ‘Agreement Of 2 M/S Asia Today Ltd. Vs Asst. Dit (Int. Taxation)-2(2)
For Appellant: Shri Niraj Sheth, Ld. A.RFor Respondent: Shri Krishna Kumar, Ld. Sr. D.R
Section 250Section 9(1)(vi)
gains of the assessee has not been computed as per the provisions of the Income-tax Act, the profit/loss has to be computed as per Rule
10(i) of the Income-tax Rules in which the global profitability can only be taken as one of the factors.
3.5.3 The assessee submits that all its activities have been carried out outside