Tuesday, 4 September 2012

S. 40(a)(i) disallowance cannot be made on basis of retrospective law

Channel Guide India Ltd vs. ACIT (ITAT Mumbai)

At the time the payments were made, the rentals for user of satellite were not chargeable to tax as "royalty" u/s 9(1)(vi) as per Asia Satellite 332 ITR 340 (Del) & B4U International and so there was no obligation of TDS. The retrospective amendment by FA 2012 cannot create an obkligation for TDS because the law cannot possibly compel a person to do something which is impossible to perform

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