VODAFONE INDIA SERVICES PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, MUMBAI

ITA 5888/MUM/2025Status: DisposedITAT Mumbai30 January 2026AY 2022-23Bench: SHRI PAWAN SINGH, JUDICIAL MEMBER SHRI GIRISH AGRAWAL (Accountant Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal found that the APA agreement between the assessee and CBDT, particularly Annexure-II concerning Critical Assumptions, covered the delay in receivables for the period in question. Furthermore, the same APA was accepted by the TPO in a subsequent assessment year. Therefore, the Tribunal found no justification for the adjustment made by the TPO/AO.

What were the facts?

The assessee, Vodafone India Services Private Limited, is an indirect subsidiary of Vodafone Group Plc. The case involves an appeal against an assessment order that included an addition for imputed interest on outstanding trade receivables. The assessee had an Advance Pricing Agreement (APA) with the CBDT which, according to the assessee, covered the realization period of invoices.

What were the issues?

Whether interest can be imputed on outstanding trade receivables when an Advance Pricing Agreement (APA) governs the realization period of invoices and if the APA was correctly considered by the revenue authorities.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13),Section 144B,Section 270A,Section 271BA,Section 92,Section 92C,Section 92D,Section 92E,Section 92B,Section 92CC

AI-generated summary — verify with the full judgment below

Cause title — parties, addresses and appearances
IN THE INCOME TAX APPELLATE TRIBUNAL “J ” BENCH, MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER (Physical hearing) Vodafone India Services Private DCIT Circle-8(3)(1) Mumbai, Aayakar Bhawan, Limited, 201-206, 2Nd Floor, M.K. Road, Mumbai-400020 Shiv Smriti Chambers, Vs 49/A, Anne Besant Road, Above Corporation Bank, Worli, S.O. Mumbai-400018, Maharashtra PAN: AAACZ 1849 D Appellant (Respondent) Assessee Represented by : Shri Ajit Jain Advocate Department Represented by : Shri Pankaj Kumar CIT-DR Date of hearing : 09.12.2025

Date of Pronouncement of Order : 30.01.2026

Order under section 254(1) of Income Tax Act

PER PAWAN SINGH, JUDICIAL MEMBER;

1.

This appeal by assessee is directed against the addition in the assessment

order passed under section 143(3)/ 144C(13) /144B dated 28.07.2025,

passed in pursuance of directions of Dispute Resolution Penal (DRP) dated

04.06.

2025 for assessment year ( A.Y.) 2022-23.The assessee has raised

following grounds of appeal;

A. General Ground (1) Assessing the total income at ₹ 418.64 crore against income of Rs. 417.28 crore filed by the assessee. B. Legal grounds (2) On the facts and circumstances of

The order continues below.

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