Income of royalty/ licence fees distributed amongst members is not taxable in company’s hand

DCIT Vs Phonographic Performance Ltd. (ITAT Mumbai)

ITAT Mumbai held that the assessee is a mere step through entity which collected the royalty and licence fees on behalf of its member and thereafter distributed the net income to the concerned members. Such distributed income cannot be taxed in the hands of the assessee

Facts-

The assessee company was entitled to collect copyright licence fee / royalty from parties like broadcast companies, etc. on behalf of its me

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