On not finding any substance in the conclusion of AO that the source of source of income is tainted, the Delhi ITAT confirms the deletion of addition made u/s 68 of Income Tax Act.The Bench comprising.
On finding that I-T Authorities had passed the same order which was earlier remanded, without proper application of mind, the New Delhi ITAT deleted the addition made by the ITOs.The Bench of Shamim.
Noting that the case has been reopened just because the assessee, i.e., a Mauritian investment company had made foreign remittance which arose from the sale of investments and there is no prima facie.
Observing that the assessee has only repatriated the amounts invested in the earlier years and hence, no taxability arises during the year, the Delhi ITAT held that there is no escapement of income in.
Emphasizing that the right to broadcast live events i.e., “Live Rights”, is not “copyright” and therefore any payment made thereto can t be said to be chargeable to tax as royalty under section.