VODAFONE INDIA SERVICES PRIVATE LIMITED ,MUMBAI vs. INCOME-TAX OFFICER, MUMBAI

ITA 4710/MUM/2024Status: DisposedITAT Mumbai28 February 2025AY 2020-21Bench: SMT. BEENA PILLAI (Judicial Member), SHRI RENU JAUHRI ( (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal directed the Assessing Officer/Transfer Pricing Officer to adopt the margin agreed under a Bilateral Advance Pricing Agreement (BAPA) with a UK AE for transactions with the US AE, citing judicial precedents. It also directed credit for TDS reflected in Form 26AS.

What were the facts?

The assessee, Vodafone India Services Private Ltd., appealed against an assessment order concerning transfer pricing adjustments for ITeS services and interest on expense recovery. The core issue involved the determination of arm's length margins for international transactions with a US Associated Enterprise (AE).

What were the issues?

Whether the margin determined for ITeS services with a US AE should align with a BAPA with a UK AE, and whether TDS credit reflected in Form 26AS should be granted.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13),Section 144B,Section 153,Section 92D,Section 92C(1),Section 234B,Section 274,Section 270A

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Income Tax Appellate Tribunal, “J” BENCH, MUMBAI

Before: SMT. BEENA PILLAI & SHRI RENU JAUHRI

For Appellant: Shri. Siddhesh Chaugule
For Respondent: Shri. Pankaj Kumar, SR. D.R
Hearing: 20.02.2025Pronounced: 28.02.2025

Per: Smt. Beena Pillai, J.M.: The Present appeal filed by the assessee arises out of final assessment order dated 19/07/2024 passed by the assessment unit of income tax department under section 143 (3) read with 2 ITA No. 4710/Mum/2024; A.Y. 2020-21 Vodafone India Services Private Limited section 144C (13) read with section 144B of the act on following grounds of appeal:

“1. 1. On the facts and in the circumstances of the case and in law, the learned Transfer Pricing Officer (Ld. TPO) and the learned Assessing Officer (L

The order continues below.

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