DCIT (TDS)(OSD)-2(3), MUMBAI vs. UBER INDIA SYSTEMS PVT LTD, MUMBAI

PER SANDEEP SINGH KARHAIL, J.M.

The present appeal has been filed by the Revenue challenging the impugned order dated 16/11/2022, passed under section 250 of the Income Tax Act, 1961 ("the Act") by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, [“learned CIT(A)”], for the assessment year 2019–20.

“1. Whether on the facts and in the circumstances of the case and law, the Ld. CIT(A) has erred in relying on the decision of Hon'ble ITAT in holding that Uber

Uber India Systems Pvt. Ltd. ITA no.126/Mum./2023

India System Pvt. Ltd. (UISPL) cannot be termed as the "Person responsible for paying" under section 204 of the IT Act without appreciating that:- (i) Uber B.V./ Uber Portier B.V. is only providing lead-generation services and the "work" of providing transportation services/food deliver services on behalf of Uber are being conducted by the driver- partners, restaurant partners & courier parnters for Uber and therefore UISPL, which is the paying entity to the driver, restaurant partners & courier parnters is the "Person responsible for paying"? (ii) Uber India System Pvt. Ltd. (UISPL) is not merely an agent of Uber B.V./ Uber Portier B.V. but also conducts all the actual business operations of the group in India and therefore the contractual relations and mutual arrangements as well as the actual conduct of parties, economic 'substance' not the 'form' would define the correct relationship of UISPL, Uber B.V./ Uber Portier B.V. and the driver- partners, restaurant partners & courier parnters to bring UISPL into its sweep of 'person responsible for paying' for purpose of section 204 of the IT Act. (iii) Since UISPL was making payment on behalf of Uber B.V./ Uber Portier B.V. for the 'work' or services rendered by driver partners, restaurant partners & courier parnters in India, it was still a "Person responsible for paying" within the meaning of section 204 of the IT Act, wherein it is mandatory that the person making the payment on behalf of some other person should also be the recipient of work or services in its own capacity. (iv) Uber B.V. is actually providing transportation services to customers in India through its digital platforms and its revenue in India are determined by the number of kilometres travelled by passenger/user of Uber BV Services? (v) Uber Portier B.V. is actually providing food deliver services to customers in India through its digital platforms Uber Eats and its revenue in India are determined by the number of orders Received/delivered through its Uber Eats App? 2. Whether on the facts and in the circumstances of the case and law, the Ld. CIT(A) failed to appreciate that the amendment u/s 204(v) of the IT Act was in nature of explaining the meaning of the expression "Person responsible for paying" in the context wherein the payment was made by a resident on behalf of a non-resident and therefore these provisions have a retrospective application. 3. Whether on the facts and in the circumstances of the case and law, the Ld. CIT(A) has erred in relying on the conclusion of hon'ble ITAT that UISPL was not a "Person responsible for paying" in terms of section 204 of IT Act has led to absurd situation, wherein even Uber B.V./ Uber Portier B.V. would not qualify as "Person responsible for paying" even though a payment is being made to driver partners, restaurant partners & courier parnters for the rendition of services in India in terms of agreement with Uber B.V./ Uber Portier B.V., and therefore the amendment u/s 204(v) must be read to be retrospective in order to cure such absurdity and propagate the intent & purposes of the Act.

Uber India Systems Pvt. Ltd. ITA no.126/Mum./2023

Uber India Systems Pvt. Ltd. ITA no.126/Mum./2023

and making payment to the drivers for the ride. The whole sequence of the order is carried out using the Uber App.

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The AO-TDS also held that the critical and important thing is that there is no requirement under the law that the person responsible for payment should be part of the agreement with the contractee. If the payee has signed a contract with a specified person defined under the section itself, whosoever is making the payment for the work is liable to deduct tax at source. Accordingly, the AO-TDS held that in the instant case, the agreement may have been signed between the driver, who is a contractor, and the specified person, which is a foreign enterprise Uber BV, but as far as the liability to deduct TDS, the same lies on the person, i.e. the assessee, who is making the payment. It is further held that the driver is the recipient of the money and there is no doubt about it. Therefore, as per the provisions of the Act, the person responsible for the payment to the driver is the person liable to deduct TDS. Accordingly, the AO- TDS held that the assessee is making substantial payments to driver partners, the restaurant partners, and the courier partners without deducting tax at source, thereby violating the provisions of Chapter XVIIB of the Act and more specifically section 194C r/w section 204 of the Act.

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responsible for paying‟ for the purpose of section 194C r/w section 204 of the Act in respect of payment made to driver partners on behalf of the Uber BV for the transportation services. Accordingly, the coordinate bench held that the assessee cannot be treated as an „assessee in default‟ under section 201(1)/201 (1A) of the Act. The relevant findings of the coordinate bench, in the aforesaid decision, are as under:-

“3.5. Person responsible for payment We find that the ld. AR vide Ground Nos. 6 to 13 had argued on the preliminary jurisdiction point that UISPL is not the "person responsible for payment" as per section 194C read with section 204 of the Act. For the sake of convenience, the relevant extract of section 194C of the Act is reproduced hereinbelow:- Section 194C "(1) Any person responsible for paying any sum to any resident (hereafter in this section referred to as the contractor) for carrying out any work (including supply of labour for carrying out any work) in pursuance of a contract between the contractor and a specified person... " 3.5.1. Hence it could be evident that on a bare reading of the aforesaid section, the following three conditions are required to be fulfilled in entirety for the department to conclude that UISPL is required to withhold taxes under Section 194C of the Act on disbursements to Driver-Partners:- (1) UISPL should be the 'person responsible for paying' as per provisions of Section 204 of the Act; (2) The disbursements to be made to the Driver-Partners should be in pursuance for carrying out any work by the Driver-Partners for UISPL; and (3) There is a contract entered into between the Driver-Partners and UISPL for the said work. 3.5.2. We find from the primary facts narrated hereinabove that UISPL does not satisfy any of the 3 conditions prescribed undersection 194C of the Act in view of the following facts:- a) UISPL makes the payment on behalf of Uber B.V. therefore UISPL is nota personresponsible for paying. b) The amount paid by UISPL is not for the purpose of carrying out any work for UISPL. c) There is no contract between UISPL and a Driver-Partner. Page | 6

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3.5.3. Hence we find that the provisions of section 194C of the Act could not come into operation at all in the instant case. Our view is further fortified by the fact that the User is also entitled to make payments in cash directly to the Driver-Partner. We hold that there cannot be any divergent stand that could be taken for a User who decides to make payment in Cash directly to the Driver-partner and for a User who decides to make digital payments. In respect of digital payments made by the User, UISPL is only a payment and collection service provider which collects the money and makes the payment on behalf of Uber B.V. Moreover, when the User directly makes cash payment to the Driver-Partner, the assessee company is not even made aware of the same. Hence expecting the assessee company i.e. UISPL in such circumstances to implead itself and deduct tax at source would only result in impossibility of performance in the hands of assessee company. The famous legal maxim would come to the rescue in this regard – LEX NON COGUT AD IMPOSSIBLIA – meaning thereby that a law cannot compel a person to perform an act which he could not possibly perform. This legal maxim has been further approved in the decision of Hon‟ble Supreme Court in the case of Krishnaswamy Bros reported in 281 ITR 305 (SC). 3.5.4. We find that the provisions of section 194C of the Act requires the person responsible for paying to a contractor, for "carrying out any work in pursuance of a contract", to deduct tax at source at 1% from the sum payable to individual contractor. We find that the UISPL is not "the person responsible for paying" for the transactions that are facilitated between a User and a Driver-Partner through the Uber App. Since the amount paid in cash is directly paid by user to the Driver-Partner and UISPL is not involved in the transaction at all, UISPL cannot be treated as a person responsible for paying when the amount is directly paid by the user to a Driver-Partner. When UISPL cannot be held as a person responsible for payment when cash is directly paid by the User to the Driver-Partner, then how the very same UISPL could be treated as a person responsible for payment when the User decides to make payments through digital means. We find that the role of UISPL is limited to act as a payment and collection service provider of Uber B.V. whereby the ride fare is collected byUISPL in its bank account on behalf of Uber B.V. and thereafter payments are made, on the instruction of Uber B.V., to Driver-Partners. 3.5.5. We find that the UISPL was brought in to the picture due to the restriction placed by the RBI vide Circular dated 22.8.2014 as detailed supra which prohibited Uber B.V. from collecting the ride fare on behalf of Driver- Partners through its bank account in the Netherlands, and was mandated to collect and disburse the rider fare to Driver-Partners through an Indian Bank Account. Pursuant to the above circular, an agreement dated 1.10.2014 was entered into between Uber B.V. and UISPL wherein UISPL was appointed as its payment and collection service provider. An application was also made by Deutsche Bank proposing to open a bank account in the name of UISPL (but on behalf of Uber B.V.) wherein ride fare and other charges will be collected by UISPL and thereafter the disbursements will be made by UISPL to Driver- Partners on behalf of Uber B.V.. We find that the ld AR also drew our attention to the relevant page nos. 817 & 818 of the paper book filed before us to prove that the bank account pursuant to the approval of the RBI is operated by Uber B.V. and none of the signatories to the bank account are employees of UISPL.

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3.5.6. We find that the provisions of section 204(iii) of the Act which defines "person responsible for paying" is also not applicable in the instant case in view of the fact that - to fall within the scope of section 204(iii) of the Act, it is necessary that a person is the payer of any sum chargeable to tax. In the instant case, UISPL is not a payer of money or liable to pay money but only a remitter of money which is collected from the Users on behalf of Uber B.V. and thereafter remitted/ disbursed at the instructions of Uber B.V. to the Driver- Partner. Hence, in the aforesaid transaction, it is User who is the person responsible for paying, as he enters into a contract with the Driver-Partner pursuant to which the transportation service is rendered by the Driver-Partner to the User . Therefore, it is submitted that the User is the person responsible for paying for the purpose of section 194C read with section 204 of the Act.Hence it could be safely concluded that UISPL cannot be treated as a person responsible for paying within the meaning of section 194C read with section 204 of the Act as it has not entered into any agreement with the Driver- Partners as stated supra. 3.5.7. We find that the reliance placed by the ld AR on the following decisions are very well founded and directly supports the view that a person being a mere remitter of money cannot be held to be a person responsible for making payment:- a) Decision of Hon‟ble Punjab and Haryana High Court in the case of Baldeep Singh vs. UOI reported in 199 ITR 628 (P&H). b) Decision of Hon‟ble Delhi High Court in the case of CIT vs. Cargo Linkers reported in 179 Taxman 151 (Del.). c) Decision of Hon‟ble Delhi High Court in the case of CIT vs. Hardarshan Singh reported in 216 Taxman 283 (Del.). d) Decision of Co-ordinate Bench of this Tribunal in the case of DCIT vs. Movies Stunt Artist reported in 6 SOT 204 (Mum.). e) Decision of Co-ordinate Bench of Indore Tribunal in the case of Chief medical Officer vs. ITO reported in 40 taxmann.com 156 3.5.8. We also find that the above views and propositions are also supported bv the circulars issued by the Central Board of Direct Taxes clarifying that an intermediary is not required to deduct tax at source. Few circulars issued in this regard are as follows:- (a) Circular No. 487 dated 8.6.1987 wherein the Board had clarified that workers employed to manufacture bidi through a medium of agency such as Munshis who manufacture bidis and after bringing bidi to factory for quality check and get the payments from Munshis, are not required to deduct tax at source while making payment to such workers. (b) Similar clarification was issued vide Circular No. 715 dated 8 August 1995 (Question No 7), wherein it was clarified that a travel agent issuing tickets on behalf of the airlines is not required to deduct tax at source as he acts on behalf of the Airlines. (c ) Further, the Board vide Circular No.5/2002 dated 30 July 2002 (Question

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No 6 & 7)once again clarified that when an individual makes payment to a travel agent for the purchase of a ticket is not subject to tax deduction at source as the privity contract isbetween the Individual passenger and the airline. 3.5.9. It is well settled that the Circulars issued by the CBDT are binding on the tax authorities. Hence taking a view contrary to what is already stated in the CBDT Circulars is not appreciated and accordingly even on this count, the assessee company i.e. UISPL cannot be treated as a person responsible for payment. 3.5.10. One more excruciating fact that needs to be considered herein is that the learned Assessing Officer while framing the income tax assessment in the hands of UISPL u/s 143(3) of the Act dated 8.12.2018 had treated the assessee company being engaged in the business of providing marketing and support services to Uber and not as a transportation service provider. Admittedly, no disallowance of expenditure u/s 40(a)(ia) of the Act was made in the hands of the assessee company for violation of provisions of Chapter XVII-B of the Act. While this is so, how can the TDS Assessing Officer take a divergent view on the same issue by changing the nature of business carried out by the assessee. 3.5.11. We further find that the legislature in its wisdom had duly provided for the relevant provisions in the Act by specifically mentioning mere remitter of money to deduct tax at source as is provided in section 204(iv) of the Act, wherein, Drawing and Disbursing Officer (DDO) i.e. the remitter of money for Government, wherever required, need to deduct tax at source being person responsible for paying. The said provision is restricted to payment made by DDO on behalf of the Government and the same cannot be extended to other payments made by outsiders. 3.5.12. Hence UISPL (i.e. the assessee company) being a mere remitter of collections made on behalf of the Driver-Partner at the direction of Uber B.V. cannot be held as the „Person responsible for paying‟ within the meaning of section 194C read with section 204 of the Act. 3.6. Applicability of provisions of section 194C of the Act We find that the Driver-Partners enter into only one agreement i.e. with UberB.V. for availing the „lead generation service‟. The relevant clauses of the said agreement which are enclosed in pages 55 to 66 of the paper book filed before us are summarised as under: a) Clause 1.14 and 1.17 - Transportation service is provided by the Driver- Partner to the User and Uber B.V. merely provides lead generation services to the Driver-Partner. b) Clause 2.2.- The Driver-Partner provides transportation services to the User at his own expense and the Driver-Partner is responsible for the transaction between them and the User. c) Clause 2.3.- Transportation service provided by the Driver-Partner to a User creates a legal and direct business relationship between them and Uber B.V. is not responsible for any action, inaction or lack of proper services of the Driver- Partner.

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d) Clause 2.4. - Uber B.V. does not control the Driver-Partner in the performance of his service and the Driver-Partner has full right to accept or reject the request received on the Uber App. e) Clause 2.5. - Driver-Partner is responsible for all obligations and liabilities that arise out of providing transportation service to the User. f) Clause 2.7.1. - Driver-Partner must use a mobile phone to receive lead generation services from Uber B.V.. g) Clause 2.8. - Driver-Partner must provide information regarding his location so as to receive lead generation services from Uber B.V.. h) Clause 3.1.- It is the Driver-Partner's responsibility to ensure that he holds a valid license, all permits and approvals under the law and possesses necessary skills to provide a transportation service. i) Clause 3.2.- It is the Driver-Partner's responsibility to ensure that the vehicles used for providing service are registered as required by law, maintained in good condition and are lawfully possessed by them. j) Clause 4.4. - Uber B.V. will charge a service fee to the Driver-Partner for providing lead generation services which will be a percentage of ride fare charged by the Driver-Partner to the User. k) Clause 4.6. - Uber B.V. will issue a receipt to the User on behalf of the Driver-Partner, for the money collected for transportation service provided by a Driver-Partner to the User. (emphasis supplied by us) 1) Clause 8 - It is the Driver-Partner's responsibility to ensure that insurance is taken for any liability that may arise on account of transportation services and/or as required by law. m) Clause 13.1. - Uber B.V. acts as an agent of the Driver-Partner for the limited purpose of collecting the payment from the User. The Driver-Partner is not an employee, agent, etc. of Uber B.V. and there is no partnership or Joint venture between Uber B.V. and the Driver-Partner. 3.6.1. Similarly, the Users wishing to avail of Uber B.V.'s lead generation services enter into agreements/ contract with Uber B.V.. The relevant clauses of the said agreement entered into between Uber B.V. and the Users which are enclosed in pages 69 to 75 of the paper book are summarized as under:- a) Clause 2 - Uber B.V. provides a technology platform to the User and the User agrees that the transportation service is not provided by Uber B.V.. Uber B.V. does not control third party transportation services availed by the User. b) Clause 3 - User must create an account for using the technology platform provided by Uber B.V. c) Clause 4 - After User receives transportation services from the Driver- Partner, Uber B.V. may, if so required by the User, facilitate the payment to be made by the User to the Driver-Partner. Page | 10

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It is open to the User by exercise of an option at will, not to avail of this facility provided by Uber B.V. and to pay the Driver-Partner directly for the transportation service availed by remitting cash payment to the Driver-Partner. d) Clause 5- Uber B.V. has no responsibility or liability related to transportation service provided by the Driver-Partner to the User. 3.6.2. From the aforesaid clauses in the relevant agreements, it could be safely concluded that Uber B.V. is involved in rendering lead generation service to the Driver-Partner and transportation service is not provided by Uber B.V. or UISPL. The transportation service is provided by the Driver-Partner to the User for which the car is arranged by the Driver-Partner, all the expenses are incurred by the Driver-Partner, necessary permits and licenses are obtained by the Driver-Partner and the liability arising out of the transaction of transportation service is assumed by the Driver-Partner.Uber B.V. is neither responsible for providing transportation service nor any liability arising out of the transportation service provided by the Driver-Partners. The transportation service provided by the Driver-Partner to Users is a contract between them to which Uber B.V. is not a party. For providing lead generation service, the Driver-Partner pays a percentage of the ride fare as a service fee to Uber B.V. Therefore, it is clear that UISPL is not a part of the contract and no payment obligation is imposed either under the agreement with the Driver-Partner or under the agreement with the User. (emphasis supplied by us) 3.6.3. Hence it could be safely concluded that the provisions of section 194C of the Act are not applicable in the instant case of the assessee as – a) UISPL is not the person responsible for making payment b) UISPL has not entered into any contract with the Driver-Partners c) no „work‟is carried out by the Driver-Partners for UISPL. 3.7. We find that the ld. AR drew our attention to the fact that Uber B.V. has been recognized as an „aggregator‟ under the Service Tax Law. Section 66B of Finance Act, 1994 provides that service tax to be paid at prescribed percentage on the value of services provided in India. Correspondingly, Rule 2(1)(d)(ii) prescribed person providing service as a Person liable for paying service tax. Section 68(2) of the Finance Act, 1994 provides that on specified services the service tax shall be paid by prescribed person. In March 2015, Central Board of Excise and Customs vide Notification No. 7/2015 dated 1.3.2015 notified that whenever an aggregator is involved in any manner in the transactions, then the person providing is not liable to pay service tax but aggregator is the person liable to pay service tax. For this purpose, Rule - 2(1)(d)(i)(AAA) of Service Tax Rules, 1994 was amended to provide that the aggregator liable to pay service tax if he is involved in the transaction in any manner. These documents are enclosed in page 90 of the paper book filed before us.Accordingly, later on, vide letter dated 27.4.2015, Uber B.V. intimated the service tax authorities that Uber B.V. has discharged its liability of service tax as an aggregator. Evidences in this regard are enclosed in Pages 82 and 88 of the Paper book filed before us. 3.7.1. From the above, again it becomes very clear that one wing of the legislature has recognized Uber B.V. as an aggregator and not a service provider which again brings us to the same point that the transportation service is provided by Driver-Partner to Users directly for which User is making the payment and it is the User who is the person responsible for making payment. Page | 11

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And, Uber B.V. and UISPL are not a party to the contract of transportation entered into between a User and a Driver-Partner. 3.8. Principle of Consistency in the assessment made bv the Department We find that the ld. AO while passing the assessment order under section 143(3) of the Act for the Asst Year 2016-17 dated 8.12.2018 had duly accepted the fact that UISPL is an entity engaged in the business of providing marketing and support services to Uber B.V. and not in the business of providing transportation service. Accordingly, no disallowance u/s 40(a)(ia) of the Act was made thereon. 3.8.1. Further, even for earlier assessment years, i.e., AY 2014-15 and AY 2015-16, when the payment was collected and disbursed directly by Uber B.V. from an account outside India, Department has not invoked provisions of section 194C of the Act for the payments made to Driver-Partners in those years. 3.8.2. Therefore, the Department has been consistently taking a view that the provision of section 194C of the Act are not applicable in the hands of UISPL and has assessed UISPL as a marketing and support service provider to Uber B.V. without making any disallowance under section 40(a)(ia). Hence, in the absence of any change in the facts and circumstances of the case, the department is not permitted to take a different view in the matter for the years under consideration. 3.9. We find lot of force in certain examples quoted by the assessee as under who operate on the similar model as employed by Uber B.V. :- (a) Similar comparison can be made with a nursing bureau (wherein nursing bureau would also get the background checks done before letting the nurse register on their portal), wherein the person interested in availing the service of a nurse and the nurse willing to render the service are put in touch by the nursing bureau. However, nursing bureau is not and cannot be held liable for deficiency in the service of a nurse. (b) Similar comparison can be made with matrimony websites apps like shaadi.com. bharat matrimony, wherein the profiles of candidates eligible for marriage are being displayed (post background checks). These apps just connects two willing candidates with each other. However, the website/ app is not and cannot be held liable for fault in the marriage of the two. 3.10. Let us now look into the issue in dispute in the context of amendment brought by Finance Act 2020 in section 204 of the Act. The amendment made in section 204 (person responsible for paying) of the Act by way of insertion of clause (v) thereon is as under:- Section 204 – For the purposes of the foregoing provisions of this Chapter and section 285, the expression “person responsible for paying” means – (i) ……………. (ii) ……………. (iii) ……………. Page | 12

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(iv) ……………. (v) in the case of a person not resident in India, the person himself or any person authorized by such person or the agent of such person in India including any person treated as an agent under section 163. 3.10.1. We find that the insertion of clause (v) in section 204 of the Act is effective only from 1.4.2020 i.e. applicable from Asst Year 2020-21 onwards and not earlier. We find that this amendment makes it very clear that any person who is authorized to make payment on behalf of a non-resident will be covered within the purview of section 204 of the Act and will be required to deduct tax at source. It is not the case of the revenue that the assessee company need to be taxed as an agent of non-resident in terms of section 163 of the Act. It is the case of the revenue that UISPL is making payment to Driver-Partners on behalf of Uber B.V. ( non-resident entity). This amendment has been specifically brought into the statute only with effect from 1.4.2020 by the Finance Act 2020 and cannot be made applicable for earlier years. This amendment cannot be held to be clarificatory in nature thereby holding it retrospective in operation as admittedly the same was not introduced with the expression „ for the removal of doubts‟. If the version of the revenue is to be accepted by holding that UISPL would be „person responsible for paying‟ as it was making payment to Driver-Partners on behalf of Uber B.V. (Non-resident) and that the said provision was always there in the statute, then there would be absolutely no necessity for the parliament to even introduce this amendment by way of insertion of clause (v) in section 204 of the Act in the Finance Act 2020 with effect from 1.4.2020. In other words, if the contention of the revenue is to be accepted for the years under consideration before us, then the entire amendment inserted by Finance Act 2020 in section 204 of the Act would become redundant and would be otiose. Hence even the subsequent amendment brought in section 204 of the Act with effect from 1.4.2020 by way of insertion of clause (v) thereon, would strengthen the stand and various contentions taken by the assessee for the years under consideration. 3.11. From the aforesaid elaborate observations in the facts and circumstances of the instant case, it could be safely concluded that UISPL cannot be treated as a „person responsible for paying‟ for the purpose of section 194C read with section 204 of the Act, for more than one reason and also the provisions of section 194C of the Act cannot be made applicable thereon. Hence the assessee company i.e. UISPL cannot be treated as an „assessee in default‟ and no order could be passed u/s 201 / 201(1A) of the Act in its hands for the years under consideration.”

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assessee provided taxi services as well as food delivery services in India through its mobile application. However, it is an accepted position that Uber EATS is a food delivery App on a similar pattern as Uber App and is a Restaurant Aggregator platform akin to Uber App being a ride-sharing platform. We find that the AO-TDS also rendered similar findings in respect of payments made under the food delivery services.

Sd/- Sd/- PRASHANT MAHARISHI SANDEEP SINGH KARHAIL ACCOUNTANT MEMBER JUDICIAL MEMBER

MUMBAI, DATED: 26/04/2023

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Copy of the order forwarded to: (1) The Assessee; (2) The Revenue; (3) The PCIT / CIT (Judicial); (4) The DR, ITAT, Mumbai; and (5) Guard file. True Copy By Order Pradeep J. Chowdhury Sr. Private Secretary Assistant Registrar ITAT, Mumbai