License fee for broadcasting sports event apportioned as 10% towards recorded events and 90% towards live coverage

Trans World Intrnational LLC Vs DCIT (ITAT Delhi)

ITAT Delhi held that apportionment of license fees as 10% towards recorded events and 90% towards live coverage instead of 5% and 95% as claimed by sports broadcasters. Accordingly, appeal partly allowed.

Facts- M/s Trans World International, Inc. (TWI Inc.) was a non-resident corporation established in Ohio, USA and was engaged in the business of production of theatrical and non-theatrical motion pictures and video tapes. During the year, the assessee submitted its receipts from resident as well as non-resid

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