The Income Tax Appellate Tribunal upheld an order of Commissioner (Appeals) and rejected I-T department's arguments that the entire income of Rs 50.92 crore was taxable.
Bachchan had contended that as per Section 80RR of the Income Tax Act, 30 per cent of the earnings that accrued to him were not taxable since he was an artist and the remaining 70 per cent, which went to the account of Amitabh Bachchan Corporation Ltd, could be taxed.
Section 80RR provides relief to an Indian artist earning foreign exchange if he brings back the remuneration to India.
However, I-T department was of the view that Bachchan was an anchor and not an artist in the television show. Moreover, the income must be earned outside India and the person should go out of India, it argued.
The payment was received from E-Entertainment Ltd, a foreign company incorporated in the British Virgin Island. The department said the entire show was shot in India at a studio in Mumbai provided by Star India Pvt Ltd and so, no tax relief should be granted.
The department had directed Bachchan to pay tax on 30 per cent of Rs 50.92 crore, saying he was not entitled to claim deduction, prompting him to approach Commissioner (Appeals).
The Commissioner had ruled in favour of the megastar. The decision has now been upheld by the Tribunal, which accepted the contention that the game show demanded exhibition of skill as an artist.