TDS deductible U/s. 194I on Composite licence fee comprising rent and royalty

CIT Vs I.T.C. Ltd. (Delhi High Court)-  In the present case, the assessee is permitted to operate an executive lounge. The question of being able to operate the lounge without the actual use of the space simply does not arise. The payment for the use of space is inseparable from the payment of royalty for the right to operate the lounge. Therefore, even applying the ratio of Japan Airlines Co. Limited v. CIT (supra) the only conclusion that can be drawn is that the payment of the sum by the assessee to the AAI under the LA falls within the expanded definition of ‘rent’ under secti...