307 ITR 59 (AAR), ISHIKAWAJIMA-HARIMA HEAVY INDUSTRIES LTD. v. DIT

124 STC 426High Court2001#5038 most cited
23

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2011 to 2025.

Sections most often in play

Section 143(3)Section 144C(13)Section 144C(5)Section 148Section 148A(b)Section 148A(d)Section 195Section 201

Issues it is cited on

section 9(l)(vii)section 206asection 206aause of equipmentsection 9(l)section 44bbsection 9(l)(vi)section 44bsection 195(2)section 91section 194jsection 90(2)

Judgments citing 307 ITR 59 (AAR), ISHIKAWAJIMA-HARIMA HEAVY INDUSTRIES LTD. v. DIT

ISAT AFRICA LIMITED FZC,UNITED ARAB EMIRATES vs. DEPUTY COMMISSIONER OF INCOME TAX, MUMBAI

In the result, the final assessment order passed by AO is set aside and the appeal of the assessee is accordingly allowed in above terms

ITA 832/MUM/2024[2018-19]Status: DisposedITAT Mumbai22 Sept 2025AY 2018-19

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhanisat Africa Limited Fzc Vs. The Deputy Commissioner Office No. 5 Pre-Fab, C Phase Ii, Of Income Tax Fujairah Free Zone Fujairah, Dubai, International Tax Circle- United Arab Emirates, Dubai - 2(2)(2) 999999 Mumbai, Maharashtra. Pan – Aagci8661Q (Appellant) (Respondent)

Section 143(3)Section 144C(5)Section 148Section 148ASection 195Section 201Section 9(1)Section 9(1)(vi)

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “I”, MUMBAI BEFORE MS. PADMAVATHY S, ACCOUNTANT MEMBER AND SHRI RAJ KUMAR CHAUHAN, JUDICIAL MEMBER iSAT Africa Limited FZC Vs. The Deputy Commissioner Office No. 5 Pre-Fab, C Phase II, of Income Tax Fujairah Free Zone Fujairah, Dubai, International Tax Circle- United Arab Emirates, Dubai - 2(2)(2) 999999 Mumbai, Maharashtra. PAN – AAGCI8661Q (Appellant) (Respondent) Assessee Represented by : Shri Dinesh Kukreja, Ld. AR Department Represented by : ShriKrishna Kumar, Ld. DR Date of conclusion of Hearing : 19.06.2025 Date of Pronouncement : 22.09.2025 O R D E R PER…

M/S. IDEA CELLULAR LIMITED,INDORE vs. THE DCIT (TDS), INDORE

Appeals are allowed

ITA 111/IND/2015[2013-14 (Quarter 4)]Status: DisposedITAT Indore01 Aug 2024

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 194Section 194HSection 194JSection 201(1)

…rious continents that would not that the process had taken place in India. ISRO SATELLITE CENTRE [ISAC], In re [2008] 307 ITR 59 (AAR), ISHIKAWAJIMA-HARIMA HEAVY INDUSTRIES LTD. v. DIT [2007] 288 ITR 408 (SC) and LAKSHMI AUDIO VISUAL INC. v. ASST. CCT [2001] 124 STC 426 (Karn) applied. (iii) That the money received from the cable operators by the operators was treated as income by these telecast operators which had in India and they had offered and paid tax. Thus, the income generated in India had been duly subjected to tax in India. The payment made by the tele cast operators situated abroad to the assessee whi…

M/S. IDEA CELLULAR LIMITED,INDORE vs. THE DCIT (TDS), INDORE

Appeals are allowed

ITA 110/IND/2015[2013-14 (for first three quarter)]Status: DisposedITAT Indore01 Aug 2024

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 194Section 194HSection 194JSection 201(1)

…rious continents that would not that the process had taken place in India. ISRO SATELLITE CENTRE [ISAC], In re [2008] 307 ITR 59 (AAR), ISHIKAWAJIMA-HARIMA HEAVY INDUSTRIES LTD. v. DIT [2007] 288 ITR 408 (SC) and LAKSHMI AUDIO VISUAL INC. v. ASST. CCT [2001] 124 STC 426 (Karn) applied. (iii) That the money received from the cable operators by the operators was treated as income by these telecast operators which had in India and they had offered and paid tax. Thus, the income generated in India had been duly subjected to tax in India. The payment made by the tele cast operators situated abroad to the assessee whi…

M/S. IDEA CELLULAR LIMITED,INDORE vs. THE DCIT (TDS), INDORE

Appeals are allowed

ITA 109/IND/2015[2012-13]Status: DisposedITAT Indore01 Aug 2024AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 194Section 194HSection 194JSection 201(1)

…rious continents that would not that the process had taken place in India. ISRO SATELLITE CENTRE [ISAC], In re [2008] 307 ITR 59 (AAR), ISHIKAWAJIMA-HARIMA HEAVY INDUSTRIES LTD. v. DIT [2007] 288 ITR 408 (SC) and LAKSHMI AUDIO VISUAL INC. v. ASST. CCT [2001] 124 STC 426 (Karn) applied. (iii) That the money received from the cable operators by the operators was treated as income by these telecast operators which had in India and they had offered and paid tax. Thus, the income generated in India had been duly subjected to tax in India. The payment made by the tele cast operators situated abroad to the assessee whi…

THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 vs. TELSTRA SINGAPORE PTE LTD.

ITA/334/2022HC Delhi24 Jul 2024

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

Section 9

…i (1991) 2 SCC 180). 69. We may also refer to the following distinction brought out by the Karnataka High Court between leasing out of equipment and the use of equipment by its customer. This was done in the case of Lakshmi Audio Visual Inc. v. Asst. CCT 124 STC 426 (Karn) in the following terms (page 433): "9. Thus if the transaction is one of leasing/hiring/letting Simpliciter under which the possession of the goods, i.e., effective and general control of the goods is to be given to the customer and the customer has the freedom and choice of selecting the manner, time and nature of use and enjoyment,…

THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 vs. TELSTRA SINGAPORE PTE LTD.

ITA/206/2023HC Delhi24 Jul 2024

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

Section 9

…i (1991) 2 SCC 180). 69. We may also refer to the following distinction brought out by the Karnataka High Court between leasing out of equipment and the use of equipment by its customer. This was done in the case of Lakshmi Audio Visual Inc. v. Asst. CCT 124 STC 426 (Karn) in the following terms (page 433): "9. Thus if the transaction is one of leasing/hiring/letting Simpliciter under which the possession of the goods, i.e., effective and general control of the goods is to be given to the customer and the customer has the freedom and choice of selecting the manner, time and nature of use and enjoyment,…

THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 vs. TELSTRA SINGAPORE PTE LTD.

ITA/61/2023HC Delhi24 Jul 2024

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

Section 9

…i (1991) 2 SCC 180). 69. We may also refer to the following distinction brought out by the Karnataka High Court between leasing out of equipment and the use of equipment by its customer. This was done in the case of Lakshmi Audio Visual Inc. v. Asst. CCT 124 STC 426 (Karn) in the following terms (page 433): "9. Thus if the transaction is one of leasing/hiring/letting Simpliciter under which the possession of the goods, i.e., effective and general control of the goods is to be given to the customer and the customer has the freedom and choice of selecting the manner, time and nature of use and enjoyment,…

THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 vs. TELSTRA SINGAPORE PTE LTD.

ITA/55/2023HC Delhi24 Jul 2024

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

Section 9

…i (1991) 2 SCC 180). 69. We may also refer to the following distinction brought out by the Karnataka High Court between leasing out of equipment and the use of equipment by its customer. This was done in the case of Lakshmi Audio Visual Inc. v. Asst. CCT 124 STC 426 (Karn) in the following terms (page 433): "9. Thus if the transaction is one of leasing/hiring/letting Simpliciter under which the possession of the goods, i.e., effective and general control of the goods is to be given to the customer and the customer has the freedom and choice of selecting the manner, time and nature of use and enjoyment,…

IDEA CELLULAR LIMITED,INDORE vs. DCIT TDS, INDORE

ITA 265/IND/2018[2010-11]Status: DisposedITAT Indore23 Apr 2024AY 2010-11

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Vodafone Idea Ltd. Cit (Tds), बनाम/ (Formerly M/S Idea Bhopal Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent) M/S Vodafone Idea Ltd. Dcit/Jcit (Tds), बनाम/ (Formerly M/S Idea Indore Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent)

Section 194HSection 194JSection 201Section 201(1)Section 250Section 254(2)Section 263

…2018 – AY 2010-11 M/s Vodafone Idea Ltd. (Formerly M/s Idea Cellular Ltd.) ISRO SATELLITE CENTRE [ISAC], In re [2008] 307 ITR 59 (AAR), ISHIKAWAJIMA-HARIMA HEAVY INDUSTRIES LTD. v. DIT [2007] 288 ITR 408 (SC) and LAKSHMI AUDIO VISUAL INC. v. ASST. CCT [2001] 124 STC 426 (Karn) applied. (iii) That the money received from the cable operators by the operators was treated as income by these telecast operators which had in India and they had offered and paid tax. Thus, the income generated in India had been duly subjected to tax in India. The payment made by the tele cast operators situated abroad to the assessee wh…

M/S. IDEA CELLULAR LIMITED,INDORE vs. THE CIT (TDS), BHOPAL

ITA 415/IND/2014[2010-11]Status: DisposedITAT Indore23 Apr 2024AY 2010-11

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Vodafone Idea Ltd. Cit (Tds), बनाम/ (Formerly M/S Idea Bhopal Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent) M/S Vodafone Idea Ltd. Dcit/Jcit (Tds), बनाम/ (Formerly M/S Idea Indore Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent)

Section 194HSection 194JSection 201Section 201(1)Section 250Section 254(2)Section 263

…2018 – AY 2010-11 M/s Vodafone Idea Ltd. (Formerly M/s Idea Cellular Ltd.) ISRO SATELLITE CENTRE [ISAC], In re [2008] 307 ITR 59 (AAR), ISHIKAWAJIMA-HARIMA HEAVY INDUSTRIES LTD. v. DIT [2007] 288 ITR 408 (SC) and LAKSHMI AUDIO VISUAL INC. v. ASST. CCT [2001] 124 STC 426 (Karn) applied. (iii) That the money received from the cable operators by the operators was treated as income by these telecast operators which had in India and they had offered and paid tax. Thus, the income generated in India had been duly subjected to tax in India. The payment made by the tele cast operators situated abroad to the assessee wh…

ASSISTANT COMMISSIONER OF INCOME TAX, (CENTRAL)-I, RAIPUR vs. MESERS CHHATTISGARH STEEL & POWER LIMITED, RAIPUR

In the result, appeal of the revenue in ITA No

ITA 92/RPR/2020[2013-14]Status: DisposedITAT Raipur18 Jul 2023AY 2013-14

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं./Ita Nos.91 & 92/Rpr/2020 "नधा"रण वष" / Assessment Years : 2012-13 & 2013-14 The Assistant Commissioner Of Income Tax, Central Circle-1, Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Chhattisgarh Steel & Power Limited. 142, Sahid Smarak, G.E Road, Raipur (C.G.) Pan : Aaccc7479G ……""यथ" / Respondent

For Appellant: Ms. Puja Bajaj, CAFor Respondent: Shri Piyush Tripathi, Sr. DR
Section 143(2)Section 143(3)Section 14ASection 40

…wer Ltd.Vs. ACIT, Central Circle-1, Raipur ITA Nos. 91 & 92/RPR/2020 Karnataka High Court between leasing out of equipment and the use of equipment by its customer. This was done in the case of Lakshmi Audio Visual Inc. vs. Asstt. Commr. of Commercial Taxes (124 STC 426), which has been followed by Hon’ble Delhi High Court in the case of Asia Satellite Telecommunications Ltd (332 ITR 340), in the following terms: "9. Thus if the transaction is one of leasing/hiring/letting simpliciter under which the possession of the goods, i.e., effective and general control of the goods is to be given to the customer and the…

ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL)-I, RAIPUR vs. MESERS CHHATTISGARH STEEL & POWER LIMITED, RAIPUR

In the result, appeal of the revenue in ITA No

ITA 91/RPR/2020[2012-13]Status: DisposedITAT Raipur18 Jul 2023AY 2012-13

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं./Ita Nos.91 & 92/Rpr/2020 "नधा"रण वष" / Assessment Years : 2012-13 & 2013-14 The Assistant Commissioner Of Income Tax, Central Circle-1, Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Chhattisgarh Steel & Power Limited. 142, Sahid Smarak, G.E Road, Raipur (C.G.) Pan : Aaccc7479G ……""यथ" / Respondent

For Appellant: Ms. Puja Bajaj, CAFor Respondent: Shri Piyush Tripathi, Sr. DR
Section 143(2)Section 143(3)Section 14ASection 40

…wer Ltd.Vs. ACIT, Central Circle-1, Raipur ITA Nos. 91 & 92/RPR/2020 Karnataka High Court between leasing out of equipment and the use of equipment by its customer. This was done in the case of Lakshmi Audio Visual Inc. vs. Asstt. Commr. of Commercial Taxes (124 STC 426), which has been followed by Hon’ble Delhi High Court in the case of Asia Satellite Telecommunications Ltd (332 ITR 340), in the following terms: "9. Thus if the transaction is one of leasing/hiring/letting simpliciter under which the possession of the goods, i.e., effective and general control of the goods is to be given to the customer and the…

DCIT 8 (3)(1), MUMBAI vs. TATA TELESERVICES (MAH.) LTD., MUMBAI

In the result, appeals filed by the revenue for assessment years 2012-2013

ITA 1059/MUM/2019[2012-13]Status: PendingITAT Mumbai31 Jan 2020AY 2012-13
For Appellant: Shri Hiten Chande (AR)For Respondent: Shri R. Manjunatha Swamy (CIT)
Section 143Section 143(3)Section 194HSection 194JSection 40

…y usefully refer to the following distinction brought out by the Karnataka High Court between leasing out of equipment and the use of equipment by its customer. This was done in the case of Lakshmi Audio Visual Inc. v. Asstt. Commr. of Commercial Taxes [2001] 124 STC 426 (Kar.), which has been followed by Hon'ble Delhi High Court in the case of Asia Satellite Telecommunications Co. Ltd. v. DIT [2011] 332 ITR 340 / 197 Taxman 263/ 9 taxmann.com 168, in the following terms: "9. Thus if the transaction is one of leasing/hiring/letting simpliciter under which the possession of the goods, i.e., effective and general c…

DCIT 8(3)(1), MUMBAI vs. TATA TELESERVICES (MAH) LTD, NAVI MUMBAI

In the result, appeal of the revenue is dismissed

ITA 2519/MUM/2015[2009-10]Status: DisposedITAT Mumbai30 Jan 2019AY 2009-10

Bench: Shri G. S. Pannu, Vice- & Shri Pawan Singhdcit-8(3)(1) M/S Tata Teleservices (Mah) Room No. 615, 6Th Floor, Ltd., D-26, Ttc Indl Area Aayakar Bhavan, M.K. Road, Midc, Sanpada, P.O. Turbhe, Mumbai-20. Navi Mumbai-400703. Vs. Pan: Aaach1458C Appellant Respondent Appellant By : Shri R. Manjunatha Swamy (Cit-Dr) Respondent By : Shri Hiten Chande (Ar) Date Of Hearing : 21.01.2019 Date Of Pronouncement : 30.01.2019 Order Under Section 254(1)Of Income Tax Act

For Appellant: Shri R. Manjunatha SwamyFor Respondent: Shri Hiten Chande (AR)
Section 14ASection 194HSection 201(1)Section 254(1)Section 40

…y usefully refer to the following distinction brought out by the Karnataka High Court between leasing out of equipment and the use of equipment by its customer. This was done in the case of Lakshmi Audio Visual Inc. v. Asstt. Commr. of Commercial Taxes [2001] 124 STC 426 (Kar.), which has been followed by Hon'ble Delhi High Court in the case of Asia Satellite Telecommunications Co. Ltd. v. DIT [2011] 332 ITR 340 / 197 Taxman 263/ 9 taxmann.com 168, in the following terms: "9. Thus if the transaction is one of leasing/hiring/letting simpliciter under which the possession of the goods, i.e., effective and general…

TATA TELESERVICES(MAHARASHTRA) LTD,NAVI MUMBAI vs. ASST CIT (TDS) 3(1), MUMBAI

In the result, all the appeals are allowed

ITA 2043/MUM/2014[2009-10]Status: DisposedITAT Mumbai27 May 2016AY 2009-10

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

For Appellant: Shri Sparsh BhargavaFor Respondent: Shri B.S. Bist
Section 133ASection 194HSection 194JSection 201(1)

…y usefully refer to the following distinction brought out by the Karnataka High Court between leasing out of equipment and the use of equipment by its customer. This was done in the case of Lakshmi Audio Visual Inc. v. Asstt. Commr. of Commercial Taxes [2001] 124 STC 426 (Kar.), which has been followed by Hon'ble Delhi High Court in the case of Asia Satellite Telecommunications Co. Ltd. v. DIT [2011] 332 ITR 340 / 197 Taxman 263/ 9 taxmann.com 168, in the following terms: "9. Thus if the transaction is one of leasing/hiring/letting simpliciter under which the possession of the goods, i.e., effective and general…

ITO (TDS), NEW DELHI vs. BHARTI AIRTEL LTD., GURGAON

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

ITA 4077/DEL/2012[2009-10 (F.Y. 2008-09)]Status: DisposedITAT Delhi17 Mar 2016

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

For Appellant: Sh. S.K. Tulsiyan, Adv., ShFor Respondent: Sh. Anuj Arora, CIT(DR)
Section 194JSection 201Section 201(1)Section 9Section 9(1)(vii)

…rious continents that would not that the process had taken place in India. ISRO SATELLITE CENTRE [ISAC], In re [2008] 307 ITR 59 (AAR), ISHIKAWAJIMA-HARIMA HEAVY INDUSTRIES LTD. v. DIT [2007] 288 ITR 408 (SC) and LAKSHMI AUDIO VISUAL INC. v. ASST. CCT [2001] 124 STC 426 (Karn) applied. ITA Nos. 3593 TO 3596/Del/2012 [Bharti Airtel Ltd. vs. ITO(TDS)] & ITA Nos. 4076 TO 4079/Del/2012 [ITO(TDS) vs. Bharti Airtel Ltd.] iii) That the money received from the cable operators by the operators was treated as income by these telecast operators which had in India and they had offered and paid tax. Thus, the income generat…

ITO (TDS), NEW DELHI vs. BHARTI AIRTEL LTD., GURGAON

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

ITA 4076/DEL/2012[2008-09 (F.Y. 2007-08)]Status: DisposedITAT Delhi17 Mar 2016

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

For Appellant: Sh. S.K. Tulsiyan, Adv., ShFor Respondent: Sh. Anuj Arora, CIT(DR)
Section 194JSection 201Section 201(1)Section 9Section 9(1)(vii)

…rious continents that would not that the process had taken place in India. ISRO SATELLITE CENTRE [ISAC], In re [2008] 307 ITR 59 (AAR), ISHIKAWAJIMA-HARIMA HEAVY INDUSTRIES LTD. v. DIT [2007] 288 ITR 408 (SC) and LAKSHMI AUDIO VISUAL INC. v. ASST. CCT [2001] 124 STC 426 (Karn) applied. ITA Nos. 3593 TO 3596/Del/2012 [Bharti Airtel Ltd. vs. ITO(TDS)] & ITA Nos. 4076 TO 4079/Del/2012 [ITO(TDS) vs. Bharti Airtel Ltd.] iii) That the money received from the cable operators by the operators was treated as income by these telecast operators which had in India and they had offered and paid tax. Thus, the income generat…

BHARTI AIRTEL LTD.,GURGAON vs. ITO (TDS), NEW DELHI

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

ITA 3596/DEL/2012[2011-12 (F.Y. 2010-11)]Status: DisposedITAT Delhi17 Mar 2016

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

For Appellant: Sh. S.K. Tulsiyan, Adv., ShFor Respondent: Sh. Anuj Arora, CIT(DR)
Section 194JSection 201Section 201(1)Section 9Section 9(1)(vii)

…rious continents that would not that the process had taken place in India. ISRO SATELLITE CENTRE [ISAC], In re [2008] 307 ITR 59 (AAR), ISHIKAWAJIMA-HARIMA HEAVY INDUSTRIES LTD. v. DIT [2007] 288 ITR 408 (SC) and LAKSHMI AUDIO VISUAL INC. v. ASST. CCT [2001] 124 STC 426 (Karn) applied. ITA Nos. 3593 TO 3596/Del/2012 [Bharti Airtel Ltd. vs. ITO(TDS)] & ITA Nos. 4076 TO 4079/Del/2012 [ITO(TDS) vs. Bharti Airtel Ltd.] iii) That the money received from the cable operators by the operators was treated as income by these telecast operators which had in India and they had offered and paid tax. Thus, the income generat…

BHARTI AIRTEL LTD.,GURGAON vs. ITO (TDS), NEW DELHI

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

ITA 3595/DEL/2012[2010-11 (F.Y. 2009-10)]Status: DisposedITAT Delhi17 Mar 2016

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

For Appellant: Sh. S.K. Tulsiyan, Adv., ShFor Respondent: Sh. Anuj Arora, CIT(DR)
Section 194JSection 201Section 201(1)Section 9Section 9(1)(vii)

…rious continents that would not that the process had taken place in India. ISRO SATELLITE CENTRE [ISAC], In re [2008] 307 ITR 59 (AAR), ISHIKAWAJIMA-HARIMA HEAVY INDUSTRIES LTD. v. DIT [2007] 288 ITR 408 (SC) and LAKSHMI AUDIO VISUAL INC. v. ASST. CCT [2001] 124 STC 426 (Karn) applied. ITA Nos. 3593 TO 3596/Del/2012 [Bharti Airtel Ltd. vs. ITO(TDS)] & ITA Nos. 4076 TO 4079/Del/2012 [ITO(TDS) vs. Bharti Airtel Ltd.] iii) That the money received from the cable operators by the operators was treated as income by these telecast operators which had in India and they had offered and paid tax. Thus, the income generat…

BHARTI AIRTEL LTD.,GURGAON vs. ITO (TDS), NEW DELHI

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

ITA 3594/DEL/2012[2009-10 (F.Y. 2008-09)]Status: DisposedITAT Delhi17 Mar 2016

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

For Appellant: Sh. S.K. Tulsiyan, Adv., ShFor Respondent: Sh. Anuj Arora, CIT(DR)
Section 194JSection 201Section 201(1)Section 9Section 9(1)(vii)

…rious continents that would not that the process had taken place in India. ISRO SATELLITE CENTRE [ISAC], In re [2008] 307 ITR 59 (AAR), ISHIKAWAJIMA-HARIMA HEAVY INDUSTRIES LTD. v. DIT [2007] 288 ITR 408 (SC) and LAKSHMI AUDIO VISUAL INC. v. ASST. CCT [2001] 124 STC 426 (Karn) applied. ITA Nos. 3593 TO 3596/Del/2012 [Bharti Airtel Ltd. vs. ITO(TDS)] & ITA Nos. 4076 TO 4079/Del/2012 [ITO(TDS) vs. Bharti Airtel Ltd.] iii) That the money received from the cable operators by the operators was treated as income by these telecast operators which had in India and they had offered and paid tax. Thus, the income generat…

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