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Culver Max Entertainment Pvt. Ltd. Vs. The CIT(A)

Case No: ITA No. 3360/MUM/2024
Court: INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “C” MUMBAI
Date: 27 Sep 2024

Parties Involved

appellantCulver Max Entertainment Pvt. Ltd.
respondentThe CIT(A)

Facts Summary

Culver Max Entertainment Pvt. Ltd. (formerly known as Sony Pictures Networks India Pvt. Ltd.) filed an appeal against the order passed by the Commissioner of Income-tax (Appeals) – National Faceless Appeal Centre, Delhi for the assessment year 2018-19. The appeal raised issues regarding the deduction of taxes paid outside India under section 37 of the Act, disallowance of the provision for gratuity, and the granting of credit for TDS and TCS. The assessee also sought relief for foreign tax credit under section 90 of the Act. The Tribunal heard the submissions of both parties and reviewed the material on record. The Tribunal found that the Commissioner of Income-tax (Appeals) had directed the Assessing Officer to verify the quantum of TDS and foreign tax credit and allow the same in accordance with law.

Decision in favour of

Assessee

Legal Issues

  • 1. Deduction of taxes paid outside India under section 37 of the Act
  • 2. Disallowance of the provision for gratuity under section 43B of the Act
  • 3. Granting credit for TDS and TCS

Judgment Outcome

Decided in favour of Assessee.

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Culver Max Entertainment Pvt. Ltd. Vs. The CIT(A) | ITA No. 3360/MUM/2024 | 2024 | Opakhya