New Delhi Television Ltd. vs. Deputy Commissioner of Income Tax
Parties Involved
Facts Summary
New Delhi Television Ltd. (NDTV), an Indian company, engaged in running television channels, had a subsidiary, NDTV Network Plc. (NNPLC), based in the United Kingdom. NNPLC issued step-up coupon bonds amounting to US$100 million in July 2007. The bonds were redeemed in November 2009 at a discounted price of US$74.2 million. The assessing officer imposed a guarantee fee on the transaction and added Rs. 18.72 crores to the income of NDTV. The revenue issued a notice to NDTV on 31.03.2015, stating that income had escaped assessment for the assessment year 2008-09. NDTV filed an appeal against the order of the High Court dismissing its writ petition challenging the notice.…
Decision in favour of
Partly Assessee / Partly Revenue
Legal Issues
- 1. Whether the revenue had a valid reason to believe that undisclosed income had escaped assessment.
- 2. Whether the assessee did not disclose fully and truly all material facts during the original assessment.
- 3. Whether the notice dated 31.03.2015 could be termed to be a notice invoking the provisions of the second proviso to Section 147 of the Act.
Judgment Outcome
Decided in favour of Partly Assessee / Partly Revenue.
Precedents Relied Upon
4 precedents cited in this judgement.