DCIT (TDS) - 2(3), MUMBAI vs. VODAFONE INDIA LTD. (FORMERLY KNOWN AS VODAFONE ESSAR LTD.), MUMBAI

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ITA 6158/MUM/2018Status: DisposedITAT Mumbai27 May 2020AY 2007-0811 pages

In favour of the assessee: the Revenue's appeal was dismissed. From the AI summary of this appeal.

AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that interconnection usage charges are not in the nature of fees for technical services and are outside the purview of TDS under Section 194J. This decision was based on previous judgments, including one from the Karnataka High Court, which found that such services operate automatically without human intervention.

What were the facts?

The Revenue appealed against an order concerning the taxability of interconnection usage charges (IUC) for the assessment year 2007-08. The core issue was whether these charges constituted fees for technical services, thus attracting TDS under Section 194J of the Income Tax Act.

What were the issues?

Whether interconnection usage charges paid by telecom companies qualify as fees for technical services for the purpose of TDS deduction under Section 194J of the Income Tax Act.

Which sections of the Income-tax Act were involved?

Section 194J

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(5)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

Income Tax Appellate Tribunal, MUMBAI “F” BENCH, MUMBAI

Before: SHRI PRAMOD KUMAR&

आदेश क� ��त�ल�प अ�े�षत / Copy of Order Forwarded to:- 1. राज�व / Revenue 2. आवेदक / Assessee 3. संबं�धत आयकर आयु�त / Concerned CIT 4.आयकर आयु�त- अपील / CIT (A) 5. �वभागीय ��त�न�ध,आयकर अपील�य अ�धकरण, मुंबई / DR, ITAT, Mumbai 6. गाड� फाइल / Guard file.

By order/आदेश से,

उप/सहायक पंजीकार, आयकर अपील�य अ�धकरण, मुंबई ।

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