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The revenue has filed these two appeals against the separate orders of the CIT(A)-55 passed u/s 143(3) r.w.s 144C(3) of the Act.
ITA No. 158 & 2770/Mum/2019 M/s BBC World Wide Media Pvt Ltd., Mumbai Since the issues in these appeals are inter linked and similar, hence are clubbed, heard and consolidated order is passed.
For the sake of convenience, we shall take up the revenue appeal in ITA No.158/Mum/2019 for the A.Y 2013-14 as a lead case and facts narrated therein. The revenue has raised the following revised grounds of appeal:

3. The A.O. on perusal of the liability side of the balance sheet found that the assessee has credited to its capital reserve a sum of Rs. 13,12,44,779/- and the details are at note-30 to the financial statements. The assessee has explained that it has received financial assistance in the form of onetime voluntary grant from BBC.WWL by way of infusion of additional funds of Rs. 5,78,55,000/-. Apart from the financial grant, which is a non interest bearing loan received by the assessee, the BBC World Wide Ltd(BWL) has waived off the amount payable by the assessee as ITA No. 158 & 2770/Mum/2019 M/s BBC World Wide Media Pvt Ltd., Mumbai collection in charge made on behalf of BBC.WL against advertising sale of BBC entertainment channel of Rs.5,63,54,389/- and the collection made on behalf of BWL on sale of motion gallery achieves of Rs.1,70,35,390/-.The AO observed that the said amounts were credited to the capital reserve and was received during the normal trading operations between the assessee and BWL, therefore a show cause notice was issued calling for the details. Against the show cause notice, the assessee has filed the submissions on 13.12.2016 referred at Para 6.2 but the A.O was not satisfied with respect to claims made by the assessee on the cessation of liability and dealt extensively on the provisions of Sec. 41(1) of the Act at Para 6.5 to 6.8 and finally made the addition of both the amounts aggregating to Rs.7,33,89,779/- along with transfer pricing adjustment of Rs. 60,68,555/- and determined the gross total income of Rs. 5,67,86,321/- and after setting off of the brought forward business loss and depreciation the total income was determined at Rs.2,37,20,670/- and the A.O. has calculated the Book profit u/s 115JB of the ITA No. 158 & 2770/Mum/2019 M/s BBC World Wide Media Pvt Ltd., Mumbai Act of Rs.4,62,27,485/- and passed the order u/s 143(3) r.w.s 144C(3) of the Act dated 28.02.2017.

4. Aggrieved by the order, the assessee has filed an appeal with the CIT(A), the CIT(A) considered the grounds of the appeal, findings of the scrutiny assessment, submissions of the assessee and provisions of law. In respect of disallowance made by the A.O applying the provisions of Sec. 41(1)(a) and 28(iv) of the Act of on waiver of amount payable by the assessee on behalf of BWL against the advertising and sale of BBC entertainment channel of Rs.5,63,54,389/- and collections made on behalf of the BWL against the sale of motion gallery of Rs. 1,70,35,390/-. The CIT(A) has dealt elaborately on the submissions of the assessee referred at Para 3.2 of the order and finally after considering the judicial decisions observed that the amount of impugned waiver being in terms of money cannot be added u/s 28(iv) of the Act and allowed the grounds of appeal. Further the assessee has raised additional ground of appeal in respect of additions made, while calculating the Book Profits under the provisions of Sec. 115JB of the Act. Whereas, the waiver amount has been ITA No. 158 & 2770/Mum/2019 M/s BBC World Wide Media Pvt Ltd., Mumbai treated as capital receipt therefore there cannot be any addition in calculation of Book Profit u/s 115JB of the Act and allowed the additional ground of appeal. The CIT(A) on the second disputed issue with respect to Transfer pricing adjustment, the CIT(A) dealt on the assessee submissions, TPO findings order and the judicial decisions. The CIT(A) relied on the assessee's own case for the A.Y 2011-12 dealt at Para 8 of the order and deleted the transfer pricing adjustment and allowed the partial relief in the other grounds and finally has partly allowed the assessee's appeal. Aggrieved by the CIT(A) order, the revenue has filed an appeal before the Hon'ble Tribunal.