TDS Triggered Only on Crystallized Liability not on Estimates: ITAT Mumbai

DCIT Vs Viacom 18 Media Pvt. Ltd. (ITAT Mumbai)

Year End Provisions Not Equal to TDS Liability- TDS Triggered Only on Crystallized Liability, Says ITAT

The dispute arose when AO, during proceedings u/s 201(1)/201(1A), noticed from Form 3CD that Viacom 18 Media Pvt. Ltd. had made year-end provisions amounting to ₹719.84 crores towards expenses falling u/s 194C, 194J, 194I & 194H. AO held that though final invoices were not received, liability had already been accounted & therefore TDS ought to have been deducted. Treating Assessee as “assessee-in-

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