Distribution Fee for Channel Distribution Not Royalty: ITAT Mumbai

Sony Pictures Networks India Pvt. Ltd. Vs DCIT (ITAT Mumbai) The Income Tax Appellate Tribunal (ITAT), Mumbai, partly allowed the appeal of the assessee for Assessment Year 2013-14 concerning transfer pricing adjustments relating to distribution fees paid to Associated Enterprises (AEs), selection of comparables, and a claim for deduction of education cess and secondary and higher education cess. The assessee was engaged in the business of distributing television channels to Local Cable Operators (LCOs), Multi System Operators (MSOs), and Direct-to-Home (DTH) operators and had reported interna...