How many judgments cite CIT v. Bharati Cellular Ltd.?

125 judgments on BharatTax cite CIT v. Bharati Cellular Ltd. (392 ITR 186), spanning 2015 to 2025.

Which sections of the Income Tax Act does CIT v. Bharati Cellular Ltd. come up under?

It is most often cited in judgments turning on Section 1961, Section 143(3), Section 9(1)(vii), Section 144C(13), Section 270A, Section 194J.

CIT v. Bharati Cellular Ltd.

392 ITR 186Supreme Court of India2017#833 most cited

What is CIT v. Bharati Cellular Ltd. authority for?

For a payment to qualify as "fees for technical services" under Section 9(1)(vii) of the Income Tax Act, direct human intervention in rendering the service is essential. Payments for automated software systems, online platforms, or database access without human involvement in delivering the service are not considered fees for technical services.

125

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2015 to 2025.

Also referred to as

CIT v Bharati Cellular Ltd · 392 ITR 186 · Section 9(1)(vii) Income Tax Act · fees for technical services · FTS definition · human intervention · automated software system · no FTS without human element · technical services DTAA · 194J TDS · Explanation 2 to Section 9(1)(vii)

Also reported as

193 Taxmann 97

Sections most often in play

Section 1961 Section 143(3)Section 9(1)(vii)Section 144C(13)Section 270A Section 194J Section 40(a)(ia)Section 9(1)(vii) of the Income Tax Act

Issues it is cited on

use of equipment copyrighted article section 9(1)(vii)fees for included services fees for technical services section 9(1)(vi)section 195(2)section 194h section 9(1)section 115a section 194j tax treaty

Judgments citing CIT v. Bharati Cellular Ltd.

Damco International A/S, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

In the result, the appeals filed by the assessee for AY 2012-13 & 2013-

ITA 933/MUM/2017[2012-13]Status: DisposedITAT Mumbai20 Jul 2020AY 2012-13

Bench: Shri Ravish Sood () & Shri N.K. Pradhan () Assessment Year: 2012-13 & Assessment Year: 2013-14

For Appellant: Mr. Porus Kaka, Sr. AdvocateFor Respondent: Mr. V. Sreekar, CIT-DR

Section 144C(13)Section 234BSection 9(1)(vi)Section 9(1)(vii)

…appellant. Thus it is explained that the total receipt of Rs.26,25,81,349/- could not be termed as managerial/technical/consultancy services. Reliance is placed on the decision by the Hon’ble Supreme Court in the case of DIT v. A.P. Moller Maersk AS (2017) 392 ITR 186 (SC). Also it is explained that reimbursement of cost of a similar nature, related to FACT, is also specifically covered in the above case. Stating that the services provided by the appellant are basically in the nature of administrative/procurement of products/coordinating services and not managerial, technical or consultancy in nature, the Ld.…

Deputy Commissioner of Income Tax, (TDS)- 2 (3), Mumbai vs. Vodafone India Limited, Mumbai

In the result, both the appeals of the Revenue are dismissed

ITA 5616/MUM/2018[2004-05]Status: DisposedITAT Mumbai22 Jun 2020AY 2004-05

Bench: Shri Mahavir Singh & Shri G. Manjunatha

For Appellant: Shri. Rahul Raman, CIT-DRFor Respondent: Shri. Ketan Ved, AR

Section 133ASection 194JSection 201(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “F”, MUMBAI BEFORE SHRI MAHAVIR SINGH, JUDICIAL MEMBER AND SHRI G. MANJUNATHA, ACCOUNTANT MEMBER ITA NOS. 5615 & 5616/MUM/2018 : A.Ys : 2003-04 & 2004-05 DCIT (TDS) – 2(3), vs. M/s. Vodafone India Ltd., Mumbai. (Appellant) Peninsula Corporate Park, Ganpatrao Kadam Marg, Lower Parel, Mumbai 400 021. PAN : AAACH5332B (Respondent) Appellant by : Shri. Rahul Raman, CIT-DR Respondent by : Shri. Ketan Ved, AR Date of Hearing : 22/06/2020 Date of Pronouncement: 22/06/2020 O R D E R PER BENCH These two appeals filed by the Revenue are directed against separate, but…

Deputy Commissioner of Income Tax, (TDS)- 2 (3), Mumbai vs. Vodafone India Limited, Mumbai

In the result, both the appeals of the Revenue are dismissed

ITA 5615/MUM/2018[2003-04]Status: DisposedITAT Mumbai22 Jun 2020AY 2003-04

Bench: Shri Mahavir Singh & Shri G. Manjunatha

For Appellant: Shri. Rahul Raman, CIT-DRFor Respondent: Shri. Ketan Ved, AR

Section 133ASection 194JSection 201(1)

DCIT (TDS) - 2(3), Mumbai vs. Vodafone India Ltd. (Formerly Known As Vodafone Essar Ltd.), Mumbai

In the result, Revenue’s appeal is dismissed

ITA 6158/MUM/2018[2007-08]Status: DisposedITAT Mumbai27 May 2020AY 2007-08

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

For Appellant: ShriKetanVed, A.R., Sr. D.R

Section 194JSection 201(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “F” BENCH, MUMBAI BEFORE SHRI PRAMOD KUMAR, VICE PRESIDENT& Ms. MADHUMITA ROY, JUDICIAL MEMBER आयकर अपील सं./I.T.A. No. 6158/Mum/2018 ("नधा"रण वष" / Assessment Year : 2007-08) The Dy.CIT(TDS)-2(3) M/s. Vodafone India Ltd. बनाम/ Mumbai Peninsula Corporate Park, Vs. Smt. K. G. Mittal GanpatraoKadamMarg, Ayurvedic Hospital Bldg., Lower Parel, Mumbai Room No. 718, Charni 400013 Road (West), Mumbai – 400 002 "थायी लेखा सं./जीआइआर सं./PAN/GIR No.: AAACH5332B .. (अपीलाथ"/Appellant) (""यथ" / Respondent) Mrs. JaantaZimikVashai, CITDR अपीलाथ" ओर से/Appellant by : ShriKetanVe…

Gemological Institute International, Inc, Mumbai vs. DCIT (It) Cir 2(3)(2), Mumbai

In the result, appeal filed by the assessee is allowed

ITA 6381/MUM/2018[2015-16]Status: DisposedITAT Mumbai19 Feb 2020AY 2015-16

Bench: Shri C.N. Prasad, Hon'Ble & Shri G. Manjunatha, Hon'Bledy. Cit (International Taxation) – 2(3)(2) Gemological Institute International, Inc V. 17Th Floor, Air India Building C/O Gia India Laboratory Pvt. Ltd., 10Th Floor, Trade Centre Nariman Point, Mumbai – 400 021 Bandra Kurla Complex, Bandra (E) Mumbai – 400 098 Pan: Aadcg6758M (Appellant) (Respondent) Assessee By : Shri J. D. Mishtry & Shri Niraj Sheth Department By : Shri V. Sreekar

For Appellant: Shri J. D. Mishtry &For Respondent: Shri V. Sreekar

Section 144C(5)

…ation in the agreement between the internal cost incurred and external cost paid by the assessee on behalf of GIA India Laboratory Pvt. Ltd. The Tribunal applying the ratio of the decision of the Hon'ble Supreme Court in the case of DIT v. A.P. Moller Maersk [392 ITR 186] held that amount 4 Gemological Institute International, Inc received towards reimbursement of cost cannot be taxed in the hands of the assessee. While holding so the Tribunal observed as under: - “7. We have considered rival submissions and perused materials on record. Undisputedly, the assessee has entered into a training and technical service…

Agc Networks Ltd, Mumbai vs. DCIT Cir 14(1)(2), Mumbai

In the result, assessee appeal stands partly allowed

ITA 2059/MUM/2017[2012-13]Status: DisposedITAT Mumbai14 Jan 2020AY 2012-13

Bench: Shri Shamim Yahya (Am) & Shri Pawan Singh (Jm)

Section 143(3)Section 144C

…n. In the present case, no income arises from any international transaction as the receipt is in the nature of reimbursement. It is an undisputed position that there is no mark-up charged. In this regards relevance is placed on A. P. Moller Maersk A S (2017) 392 ITR 186 (SC) in para 11, page no. 192. Further, the appellant is the parent company of Aegis Network Pte Limited. With a view to guide its subsidiary as well as monitor its functioning, the appellant's CEO, CSO, marketing personnel, finance & legal personnel, supply chain employees, sales executives etc. have spent certain time for its subsidiary. In vie…

Cma Cgm Agencies India Private Limited, Pune vs. Deputy Commissioner of Income-Tax, Range -1(1), Pune

In the result, the appeal is allowed

ITA 2314/PUN/2017[2012-13]Status: DisposedITAT Pune02 Jan 2020AY 2012-13

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviिनधा"रण वष" / Assessment Year : 2012-13 Cma Cgm Agencies India Private Vs. Dcit, Range-1(1), Limited, Pune 407, City Tower Floor, Boat Club Road, Pune – 411 001 Pan : Aadcc3951G Appellant Respondent

Section 143(3)Section 40Section 9(1)(vi)Section 9(1)(vii)

…e Royalty/Fees for technical services. The Tribunal upheld the action of the CIT(A) in treating the amount as profit derived from operation of ships. Eventually, when this matter came up before the Hon’ble Supreme Court in DIT Vs. A.P. Moller Maersk (2017) 392 ITR 186 (SC), their Lordships held that the High Court was correct in holding that the income from the use of Global Telecommunication Facility called 'Maersk Net' was income arising out of shipping business and not as `Fees for technical services’. In reaching this conclusion, the Hon’ble Supreme Court noted that the communication system in question w…

Cma Cgm Sa, Mumbai vs. DCIT (It) - 2(1)(2), Mumbai

In the result, assessee’s appeal is partly allowed

ITA 6095/MUM/2018[2015-16]Status: DisposedITAT Mumbai30 Dec 2019AY 2015-16

Bench: Shri Saktijit Dey & Shrimanoj Kumar Aggarwal

For Appellant: Shri M.P. Lohia a/wFor Respondent: Shri Samuel Darse

Section 143(3)Section 144C(13)Section 172Section 44B

…Hon'ble Jurisdictional High Court in DIT v/s Balaji Shipping U.K. Ltd., which is on the issue of slot chartering and not on IHC. In this context, learned DRP also referred to the decision of the Hon'ble Supreme Court in DIT v/s A.P. Moller Maersk A/S, [2017] 392 ITR 186 (Bom.). Learned DRP also observed, the decision rendered by the Hon'ble Jurisdictional High Court in case of SAF Marine Container Lines NV (supra) appeared to be due to some confusion. Thus, the DRP ultimately concluded that the decision of the Tribunal and the decision of the Hon'ble Jurisdictional 5 CMA CGM SA High Court in SAF Marine Contain…

Sodexo Svc India Private Limited, Mumbai vs. Deputy Commissioner of Income Tax (TDS)-2(2), Mumbai

In the result, the appeals are allowed for statistical purposes

ITA 933/MUM/2019[2014-15]Status: DisposedITAT Mumbai07 Oct 2019AY 2014-15

Bench: Shri Pawan Singh () & Shri N.K. Pradhan () Assessment Year: 2013-14 & Assessment Year: 2014-15 & Assessment Year: 2015-16 & Assessment Year: 2016-17 Sodexo Svc India Pvt. Ltd., Assistant/Deputy 503 & 504, 5Th Floor, B Wing, Vs. Commissioner Of Income Hiranandani Fulcrum, Sahar Tax (Tds)-2(2), 717, Smt. Road, Andheri East, Mumbai. K.G. Mittal Ayurvedic Hospital Bldg., Charni Road (W), Mumbai. Pan No. Aalcs9822Q Appellant Respondent Assessee By : Mr. F.B. Andhyarujina, Mr. Gautam Thacker, Mr. Yazdi P. Jijina & Ms. K.R. Daviervala, Ars Revenue By : Mr. B.B. Rajendra Prasad, Cit-Dr Last Date Of Hearing : 12/07/2019 Date Of Pronouncement: 07/10/2019

For Appellant: Mr. F.B. AndhyarujinaFor Respondent: Mr. B.B. Rajendra Prasad, CIT-DR

Section 133ASection 194CSection 201Section 201(1)Section 7

…exo SVC India Pvt. Ltd. the affiliates, the Ld. counsel rely on the decision in Vijay Ship Breaking Corporation v. CIT [2009] 314 ITR 309 (SC), GE India Technology Centre P. Ltd. v. CIT [2010] 327 ITR 456 (SC), DIT (Int. Tax.) v. A.P. Moller Maersk A/S [2017] 392 ITR 186 (SC), CIT v. Industrial Engineering Projects P. Ltd. [1993] 202 ITR 1014 (Del), CIT v. DLF Commercial Projects Corporation [2015] 379 ITR 538 (Del), ADIT (IT) v. Wizcraft International Entertainment P. Ltd. [2011] 8 ITR (Trib) 334 (Mum) . Further reliance is placed by the Ld. counsels on the decision in East India Hotels Ltd. v. CBDT (2010) 320 I…

Deputy Commissioner of Income Tax, (TDS)- 2 (3), Mumbai vs. Vodafone India Limited, Mumbai

In the result, the appeals filed by the Revenue are dismissed

ITA 5612/MUM/2018[2000-01]Status: DisposedITAT Mumbai18 Sept 2019AY 2000-01

Bench: Shri C.N. Prasad () & Shri N.K. Pradhan () Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03

For Appellant: Mr. Deepak Chopra, ARFor Respondent: Mr. Sushil Kumar Poddar, DR

Section 133ASection 194JSection 2Section 201(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “F”, MUMBAI BEFORE SHRI C.N. PRASAD (JUDICIAL MEMBER) AND SHRI N.K. PRADHAN (ACCOUNTANT MEMBER) Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 The Dy. CIT(TDS)-2(3), M/s Vodafone India Ltd. Mumbai, Smt. K.G. Mittal Vs. (formerly known as Ayarvedic Hospital, Bldg, Vodafone Essar Ltd.), Room No. 718 Charni Peninsula Corporate Park, Road (West), Mumbai- Ganpatao Kadam Marg, 400002. Lower Parel, Mumbai- 400021. PAN:AAACH5332B Appellant Respondent Revenue by : Mr. Sushil Kumar Poddar, DR Assessee by : Mr. Deepak Chopra, AR Date of…

Renaissance Services Bv, Mumbai vs. DDIT (It) 2(1), Mumbai

In the result, both the appeal filed by assessee is allowed

ITA 5678/MUM/2016[2011-12]Status: DisposedITAT Mumbai09 Aug 2019AY 2011-12

Bench: Shri G.S. Pannu, Vice- & Shri Pawan Singh

For Appellant: Shri Paras Savla with Shri Pratik Poddar (AR)For Respondent: Shri Nishant Samaiya

Section 254(1)

…ices’ provided by Stock Exchange, as the same were not services which were specifically sought for by the user or consumer. The Hon’ble Apex Court following the aforesaid view, had thereafter observed in the case of CIT (IT)-1 Vs. A.P Moller Maersk A S (2017) 392 ITR 186 (SC), that where the assessee, a foreign shipping company had set up a telecommunication system in order to enable its agents across globe including India to perform their role more effectively, the payment received for providing such facility was not taxable as fee for technical services. We have perused the facts of the case before us and after…

M/S. Hella India Lighting Ltd., New Delhi vs. DCIT, New Delhi

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 1109/DEL/2015[2010-11]Status: DisposedITAT Delhi29 Jul 2019AY 2010-11

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastavaassessment Year: 2010-11 Hella India Lighting Ltd., Vs Dcit, B-13, Badarpur Extension, Circle-11(1), New Delhi. New Delhi. Pan: Aaacj0101G (Appellant) (Respondent) Assessee By : Dr. Rakesh Gupta, Advocate & Shri Somil Aggarwal, Advocate Revenue By : Shri Sanjay I Bara, Cit, Dr Date Of Hearing : 16.05.2019 Date Of Pronouncement : 29.07.2019 Order Per R.K. Panda, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 23Rd December, 2014 Passed By The Dcit, Circle 11(1), New Delhi U/S 143(3) Read With Section 144C Of The It Act, 1961 For Assessment Year 2010-11. 2. Facts Of The Case, In Brief, Are That The Assessee Is A Company Engaged In The Business Of Manufacturing Of Automobile Components Including Head Lamps, Tail Lamps, Horns Switches, Bulbs, Sundry Lamps, Wiper Arms & Wiper Blades. It Filed Its Return Of Income On 5Th October, 2010 Declaring A Loss Of Rs.1,46,71,148/-. Since The Assessee Has Undertaken International Transactions With Its Ae, The Assessing Officer

For Appellant: Dr. Rakesh Gupta, Advocate &For Respondent: Shri Sanjay I Bara, CIT, DR

Section 143(3)Section 144CSection 40a

…companies is also not chargeable to tax as FTS since the AE does not have any PE in India. For the above proposition, he relied on the decision of the Hon'ble Supreme Court in the case of DIT 12 (International Taxation) vs. A.P. Moller Maersk AS reported in 392 ITR 186. The ld. DR, on the other hand, strongly relied on the order of the A.O./TPO/DRP. 14. We have considered the rival arguments made by both the sides and perused the orders of the A.O./TPO/DRP and the paper book filed on behalf of the assessee. We have also considered the various decisions cited before us. We find the Assessing Officer, in the…

At & T Global Network Services (India) Pvt. Ltd., New Delhi vs. Addl. CIT, Special Range- 1, New Delhi

Appeal of the assessee is partly allowed for statistical purpose

ITA 7001/DEL/2018[2014-15]Status: DisposedITAT Delhi18 Jul 2019AY 2014-15

Bench: Shri N. K. Billaiya & Ms Suchitra Kamble

Section 143(3)Section 144C

…1 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘I-1’ NEW DELHI BEFORE SHRI N. K. BILLAIYA, ACCOUNTANT MEMBER AND MS SUCHITRA KAMBLE, JUDICIAL MEMBER I.T.A. No. 7001/DEL/2018 (A.Y. 2014-15) AT & T Global Network Vs. Additional Commissioner of Services (India) Income Tax Private Limited Special Range-1 Mohan Dev House, Tolstoy New Delhi Marg, New Delhi - 110001 (APPELLANT) (RESPONDENT) Appellant by Sh. Kanchun Kaushal, AR Respondent by Sh. Sanjay I. Bara, CIT-DR Date of Hearing 15.07.2019 Date of Pronouncement 18.07.2019 ORDER PER SUCHITRA KAMBLE, JM This appeal is filed against the order dated 28…

Hsbc Bank Plc, Mumbai vs. DCIT (It) 2(2)(2), Mumbai

In the result, the appeal of the assessee is allowed, as above

ITA 7386/MUM/2016[2011-12]Status: DisposedITAT Mumbai16 Jul 2019AY 2011-12

Bench: Shri G.S. Pannu & Shri Ram Lal Negi: A.Y : 2011-12

For Appellant: Shri Farrokh Irani &For Respondent: Shri S. Anbuselvan &

Section 143(3)Section 234B

…the assessee, particularly on the facts of the case, cannot be treated as 4 HSBC Bank Plc income in the hands of the assessee. In support of his contentions, the Learned Representative relied on the following judgments : i) DIT (IT) v. A P Moller Maersk AS, 392 ITR 186 (SC) ii) CIT v. Siemens Aktiongeselschaft, 310 ITR 320 (Bom) 6. The ld. DR appearing for the Revenue, on the other hand, relied upon the orders of the authorities below and submitted that the onus is on the assessee to produce all the evidences of expenditure and that this onus is clearly not discharged by the assessee. 7. We have carefully con…

ITO 12(3)(2), Mumbai vs. Keshma Impex P.Ltd, Mumbai

In the result, appeal of the revenue is dismissed and Cross

ITA 767/MUM/2016[2010-11]Status: DisposedITAT Mumbai10 Jul 2019AY 2010-11

Bench: Shri M.Balaganesh, Am & Shri Amarjit Singh, Jm Income Tax Officer- Vs. M/S. Keshma Impex Pvt.Ltd 12(3)(2) P-28, M.R. Housing Society Room No.147A, 1St Floor Relief Road, Aayakar Bhavan Opp. Raheja College M.K.Road, Santacruz (W) Mumbai – 400 020 Mumbai – 400 054 Pan/Gir No.Aabck5728R (Appellant) .. (Respondent) Co No.54/Mum/2018 (Arising Out Of Ita No.767/Mum/2016) (Assessment Year :2010-11) M/S. Keshma Impex Pvt.Ltd Vs. Income Tax Officer- P-28, M.R. Housing Society 12(3)(2) Room No.147A, 1St Floor Relief Road, Opp. Raheja College Aayakar Bhavan Santacruz (W) M.K.Road, Mumbai – 400 054 Mumbai – 400 020 Pan/Gir No.Aabck5728R (Appellant) .. (Respondent)

Section 143(3)Section 195Section 37(1)

…to cost basis without any profit element. These evidences are enclosed in pages 102 and 103 of the paper book. It is now well settled by the decision of the Hon’ble Supreme Court in the case of DIT (International Transaction) vs. AP Moller Maersk reported in 392 ITR 186 (SC) wherein it has been categorically held that if there is no profit element embedded in payments and if the payments are mere reimbursement and expenses, there would be no requirement of deduction of tax at source as there would be no income chargeable to tax in India in the hands of the said non-resident. Similar view was also taken by the de…

DCIT 4(3)(1), Mumbai vs. Tapi Energy Projects Ltd., Mumbai

In the result, appeals filed by the assessee for all assessment years are allowed

ITA 7267/MUM/2018[2013-14]Status: DisposedITAT Mumbai28 Jun 2019AY 2013-14

Bench: Shri Saktijit Dey & Shri G. Manjunatha, Assessment Year: 2013-14

Section 143(3)Section 144C(13)Section 234BSection 234CSection 271Section 9Section 9(1)(vi)

…e is no material on record to demonstrate that while providing access to the database there is any human intervention. As held by the Hon'ble Supreme Court in CIT v/s Bharati Cellular Ltd., [2010] 193 taxman 97 (SC) and DIT v/s A.P. Moller Maersk A.S., [2017] 392 ITR 186 (SC), for providing technical / managerial service human intervention is a sin qua non. Further, Article– 12(4) of India–Germany Tax Treaty provides that payment for the service of managerial, technical or consultancy nature including the provisions of services by technical or other personnel can be termed as fees for technical services. None of…

Elsevier Information Systems Gmbh, Mumbai vs. DCIT (It) 2(2)(1), Mumbai

In the result, appeals filed by the assessee for all assessment years are allowed

ITA 6573/MUM/2016[2013-14]Status: DisposedITAT Mumbai28 Jun 2019AY 2013-14

Bench: Shri Saktijit Dey & Shri G. Manjunatha, Assessment Year: 2013-14

Section 143(3)Section 144C(13)Section 234BSection 234CSection 271Section 9Section 9(1)(vi)

At & T Global Network Services (India) Pvt. Ltd., New Delhi vs. JCIT, Special Range-1, New Delhi

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

ITA 7115/DEL/2017[2013-14]Status: DisposedITAT Delhi27 May 2019AY 2013-14

Bench: Shri R.K. Panda & Smt. Beena A. Pillai

For Appellant: Shri Kanchan Kaushal, AdvocateFor Respondent: Shri H.K. Choudhary, CIT, DR

Section 143(3)Section 144CSection 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH : FRIDAY I-2 : NEW DELHI BEFORE SHRI R.K. PANDA, ACCOUNTANT MEMBER AND SMT. BEENA A. PILLAI, JUDICIAL MEMBER ITA Nos.5535/Del/2016 & 7115/Del/2017 Assessment Years: 2012-13 & 2013-14 AT & T Global Network Services Vs JCIT, (India) Pvt. Ltd., Special Range-1, Vatika Triangle, 3rd Floor, New Delhi. Sushant Lok-1, Block-A, Gurgaon. PAN: AAFCA8810L (Appellant) (Respondent) Assessee by : Shri Kanchan Kaushal, Advocate Revenue by : Shri H.K. Choudhary, CIT, DR Date of Hearing : 28.02.2019 Date of Pronouncement : 27.05.2019 ORDER PER R.K. PANDA, AM: The above two appea…

M/S at & T Global Network Services (India) Pvt. Ltd., Gurgaon vs. JCIT, New Delhi

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

ITA 5535/DEL/2016[2012-13]Status: DisposedITAT Delhi27 May 2019AY 2012-13

Bench: Shri R.K. Panda & Smt. Beena A. Pillai

For Appellant: Shri Kanchan Kaushal, AdvocateFor Respondent: Shri H.K. Choudhary, CIT, DR

Section 143(3)Section 144CSection 92C

DCIT (It) 4(1)(1), Mumbai vs. Reliance Jio Infocomm Ltd, Mumbai

The appeal of the revenue is dismissed

ITA 936/MUM/2017[2016-17]Status: DisposedITAT Mumbai10 May 2019AY 2016-17

Bench: Shri M. Balaganesh & Shri Ravish Sooddeputy Commissioner Of Income M/S Reliance Jio Infocomm Ltd., Tax (It)-4(1)(1), 9Th Floor, Maker Chambers Iv, Room No.- 1712, 222 Nariman Point, Vs. Air India Building, Mumbai – 400 021 Nariman Point, Mumbai – 400021 Pan – Aabci6363G (Appellant) (Respondent)

For Appellant: Shri Nishant Samaiya, D.RFor Respondent: Shri Sunil Moti Lala &

Section 195Section 195ASection 248

…P a g e | 1 ITA No. 936/Mum/2017 A.Y. 2016-17 Deputy Commissioner of Income tax (IT)-4(1)(1) Vs. M/s Reliance Jio Infocomm Ltd. IN THE INCOME TAX APPELLATE TRIBUNAL “I” Bench, Mumbai Before Shri M. Balaganesh, Accountant Member and Shri Ravish Sood, Judicial Member Deputy Commissioner of Income M/s Reliance Jio Infocomm Ltd., Tax (IT)-4(1)(1), 9th Floor, Maker Chambers IV, Room No.- 1712, 222 Nariman Point, Vs. Air India Building, Mumbai – 400 021 Nariman Point, Mumbai – 400021 PAN – AABCI6363G (Appellant) (Respondent) Appellant by: Shri Nishant Samaiya, D.R Respondent by: Shri Sunil Moti Lala & Shri Bhavya Su…