Disallowance u/s 40(a)(ia) should not be made on the basis of subsequent amendments

The amendment brought in by the Finance Act with retrospective effect, which was passed in the year subsequent to the year under consideration, should not be considered for penalizing the assessee by way of dis allowance u/s 40(a)(ia) of the Act. The Ld Counsel submitted that the Hon’ble Delhi High Court in the case of Asia Satellite Telecommunications Co. Ltd Vs. DIT (332 ITR 340) had taken the view that the transmission of television signals through Satellite / transponders would not fall in the category of “royalty” as defined under Explanat

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