UNITED BREWERIES LTD,,SRIKAKULAM vs. JCIT TDS RANGE, VISAKHAPATNAM
In the result, appeals of the assessee are dismissed
ITA 454/VIZ/2017[2008-2009]Status: DisposedITAT Visakhapatnam14 Mar 2018AY 2008-2009
Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकरअपीलसं./I.T.A.No.454-456/Viz/2017 ("नधा"रणवष"/Assessment Year:2008-09, 2009-10 & 2010-11) M/S United Breweries Ltd., Vs. Jt. Commissioner Of (Successor To M/S United Millenium Income Tax Breweries Ltd.,) Tds Range Bantupalli Village Visakhapatnam Ranasthalam Mandalam Srikakulam Dt. [Pan :Aaacu6053C] (अपीलाथ"/ Appellant) (""थ"/ Respondent) : Shri Y.A.Rao, Ar अपीलाथ"क"ओरसे/ Appellant By : Shri Deba Kumar Sonowal, Dr ""यथ"क"ओरसे / Respondent By सुनवाईक"तार"ख / Date Of Hearing : 27.02.2018 घोषणाकीतारीख/Date Of Pronouncement 14.03.2018 :
For Appellant: Shri Deba Kumar Sonowal, DR
Section 194Section 194CSection 194JSection 201
271(1)(c). However, factual and legal matrix in the present case are totally different. Factually, as already discussed above, the plain terms of the Brewing Agreement clearly show that the impugned payments were made towards royalty and not towards any contract work. The assessee company is a party to the agreement and has also submitted that the payments were
