No liability to deduct TDS if income not chargeable to tax in the hands of recipient

Zee Entertainment Enterprises Ltd. Vs ITO (ITAT Mumbai)

It is undisputed that the Hon’ble Delhi High Court has held that the payment is not taxable in the hands of the recipient. Respectfully following the precedent of the Hon’ble Apex Court in the case of E. Technology Centre Pvt. Ltd. (supra), we are of the considered opinion that when this income is not chargeable to tax in the hands of the recipient, no liability is there on the assessee to deduct tax at source. Accordingly, in the background of

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