BBC World Service India Pvt. Ltd Vs ACIT (ITAT Delhi)
Income Tax Appellate Tribunal (ITAT), Delhi Bench, has quashed the assessment order for the assessment year 2017-18 against BBC World Service India Private Limited. The Tribunal’s decision, pronounced on February 7, 2025, determined that the final assessment order was issued beyond the statutory period of limitation, rendering it invalid.
The appeal by BBC World Service India Private Limited challenged an assessment order dated May 26, 2022, issued under Section 143(3) read with Section 144C(13) of the Income Tax Act, 1961. The core argument presented by the assessee’s counsel was that the order was time-barred.
BBC World Service India Private Limited is engaged in producing program content for its UK parent company, British Broadcasting Corporation (BBC, UK), and other group entities. Its revenue primarily stems from service fees from BBC UK and programming fees from licensing content for various media platforms. The company filed its income tax return on November 30, 2017, declaring a total income of Rs. 6,39,12,880.
A draft assessment order was issued on March 31, 2021, under Section 143(3) read with Section 144C of the Act. This order included a transfer pricing adjustment of Rs. 2,19,68,636, which was added to the company’s total income. Following this, BBC World Service India Private Limited filed objections with the Dispute Resolution Panel (DRP).
