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21 Culver Max Entertainment Pvt. Ltd. vs. ACIT
ITA Nos. 7685/Mum/2019 and 925/Mum/2021
Assessment Years: 2015–16 & 2016–17
Date of Order: 02nd May, 2024
Section: 199
The resulting company in case of demerger and the Transferee Company in the case of transfer are eligible to claim TDS credit, even if the TDS certificates are in the name of the demerged company / Transferor Company.
FACTS
MSM Satellite (Singapore) Pte Ltd. (MSN Singapore) a wholly owned subsidiary of the assessee purchased, in March 2005, a TV channel named “SAB TV” from a company named Shri Adhikari Brothers. Subsequently, during the financial year 2014–15 MSN Singapore demerged its broadcasting business and the same was taken over by the assessee herein. The demerger scheme was sanctioned by the Bom
