CIT v. Estel Communication (P.) Ltd.

318 ITR 185High Court2009#4679 most cited

What is CIT v. Estel Communication (P.) Ltd. authority for?

Where services may fall into the category of consultancy services, their taxability in the context of technical, managerial, and consultancy services can be examined, especially when such services may overlap.

25

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2014 to 2025.

Also referred to as

CIT v. Estel Communication P. Ltd. · 318 ITR 185 · section 9(1)(vii) · section 195 · fees for technical services · tax treaty · non-resident · technical services · consultancy services · managerial services

Sections most often in play

Section 195Section 37(1)Section 40(a)(ia)Section 80G

Issues it is cited on

section 9(1)(vii)section 195section 40(a)(i)section 9(1)fees for technical servicestax treatysection 40(a)(ia)section 40(a)non-residentsection 19section 40company

Judgments citing CIT v. Estel Communication (P.) Ltd.

SOLVAY S A ,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX INTERNATIONAL TAX CIRCLE 4(2)(2), MUMBAI

In the result, the appeal is partly allowed

ITA 2071/MUM/2025[2022-23]Status: DisposedITAT Mumbai27 Oct 2025AY 2022-23
Section 143(3)Section 9(1)(vii)

…ll in the category of consultancy services.\nParagraphs 41 and 42 do not emanate for consideration in the present case, and effect\nthereof can be examined in an appropriate case [However, see Commissioner of Income\nTax vs. Estel Communication P. Ltd. (2009) 318 ITR 185 (Del) and Skycell\nCommunications Ltd. (supra)].\n\n25.\nThus, the technical services consists of services of technical nature, when special\nskills or knowledge relating to technical field are required for their provision,\nmanagerial services are rendered for performing management functions and\nconsultancy services relate to provision of advic…

DY. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 2(3), MUMBAI vs. HINDUJA GLOBAL SOLUTIONS LIMITED, MUMBAI

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

ITA 2424/MUM/2025[2020-21]Status: DisposedITAT Mumbai09 Jun 2025AY 2020-21

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiyaआयकर अपील सुं./Ita No. 2423/Mum/2025 (नििाारण वर्ा / Assessment Year :2012-13) आयकर अपील सुं./Ita No. 2424/Mum/2025 (नििाारण वर्ा / Assessment Year :2020-21)

For Appellant: NoneFor Respondent: Shri Ritesh Misra a/w Shri
Section 195Section 40

…he overseas branch, the assessee has deducted tax as per the Philippines tax law. The CIT(A) deleted the disallowance of Rs. 3,94,00,000/-, further drawing support from the decision of the Hon’ble Delhi High Court in the case of Estel Communications Pvt. Ltd. 318 ITR 185. P a g e | 4 ITA No. 2423 & 2424/Mum/2025 A.Y. 2012-13 & 2020-21 Hinduja Global Solutions Ltd. 9. Before us, DR strongly supported the findings of the AO but could not bring any distinguishing decision in favour of the revenue, nor could point out any error or infirmity in the findings of the CIT(A). 10. After giving a careful consideration to th…

DY. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 2(3), MUMBAI, MUMBAI vs. HINDUJA GLOBAL SOLUTIONS LIMITED, MUMBAI

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

ITA 2423/MUM/2025[2012-13]Status: DisposedITAT Mumbai09 Jun 2025AY 2012-13

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiyaआयकर अपील सुं./Ita No. 2423/Mum/2025 (नििाारण वर्ा / Assessment Year :2012-13) आयकर अपील सुं./Ita No. 2424/Mum/2025 (नििाारण वर्ा / Assessment Year :2020-21)

For Appellant: NoneFor Respondent: Shri Ritesh Misra a/w Shri
Section 195Section 40

…he overseas branch, the assessee has deducted tax as per the Philippines tax law. The CIT(A) deleted the disallowance of Rs. 3,94,00,000/-, further drawing support from the decision of the Hon’ble Delhi High Court in the case of Estel Communications Pvt. Ltd. 318 ITR 185. P a g e | 4 ITA No. 2423 & 2424/Mum/2025 A.Y. 2012-13 & 2020-21 Hinduja Global Solutions Ltd. 9. Before us, DR strongly supported the findings of the AO but could not bring any distinguishing decision in favour of the revenue, nor could point out any error or infirmity in the findings of the CIT(A). 10. After giving a careful consideration to th…

SPRINGER NATURE CUSTOMER SERVICES CENTRE GMBH,NEW DELHI vs. JCIT, INTERNATIONALO TAXATION, CIRCLE-3(1)(2), NEW DELHI

In the result, the appeal of the assessee is partly allowed

ITA 2534/DEL/2019[2013-14]Status: DisposedITAT Delhi14 Oct 2022AY 2013-14

Bench: Shri Shamim Yahya & Shri Kul Bharat[Assessment Year : 2013-14] Springer Nature Customer Services Vs Jcit Centre Gmbh (Earlier Known As (International Taxation), Springer Customer Centre Gmbh), Circle-3(1)(2), 7Th Floor, Vijaya Building, New Delhi. 17-Barakhamba Road, New Delhi-110001. Pan-Aascs1092B Appellant Respondent Appellant By S/Shri Himanshu Sinha, Bhuwan Dhooper & Vibhu Gupta, Advocates Respondent By Ms. Rashmita Jha, Cit Dr Date Of Hearing 20.09.2022 Date Of Pronouncement 14.10.2022

Section 143(3)Section 234ASection 234BSection 271Section 9(1)(vi)

…fall in the category of consultancy services. Paragraphs 41 and 42 do not emanate for consideration in the present case, and effect thereof can be examined in an appropriate case [However, see Commissioner of Income Tax vs. Estel Communication P. Ltd. (2009) 318 ITR 185 (Del) and Skycell Communications Ltd. (supra)]. 25. Thus, the technical services consists of services of technical nature, when special skills or knowledge relating to technical field are required for their provision, managerial services are rendered for performing management functions and consultancy services relate to provision of advice by som…

M/S. INFOSYS BPO LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-1(1), BANGALORE

In the result, appeal by the assessee is allowed

ITA 989/BANG/2017[2016-17]Status: DisposedITAT Bangalore01 Sept 2022AY 2016-17

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(It)A No.989/Bang/2017 Assessment Year : 2016-17 M/S. Infosys Bpo Limited Vs. The Deputy Commissioner Of Income Electronic City, Hosur Road, Tax, Bengaluru – 560 100. International Taxation, Pan : Aaccp 4478 N Circle 1(1), Bengaluru. Appellant Respondent Appellant By : Shri. Padam Chand Khincha, Ca Respondent By : Shri. K. R. Narayana, Addl. Cit(Dr)(Itat), Bengaluru Date Of Hearing : 25.08.2022 Date Of Pronouncement : 01.09.2022 O R D E R Per N. V. Vasudevan: This Is An Appeal By The Assessee Against The Order Dated 28.02.2017 Of Cit(A) - 12, Bengaluru, Relating To Assessment Year 2016-17. 2. The Assessee Is A Company Engaged In The Business Of Rendering Bpo Services. The Assessee Made Payment Of 2100 Us$ To A Non- Resident Viz., Stakeholder Centered Coaching (International Ltd.,)

For Appellant: Shri. Padam Chand Khincha, CAFor Respondent: Shri. K. R. Narayana, Addl. CIT(DR)(ITAT), Bengaluru
Section 248Section 5Section 9(1)(vii)

…fall in the category of consultancy services. Paragraphs 41 and 42 do not emanate for consideration in the present case, and effect thereof can be examined in an appropriate case [However, see Commissioner of Income Tax vs. Estel Communication P. Ltd. (2009) 318 ITR 185 (Del) and Skycell Communications Ltd. (supra)]. 25. Thus, the technical services consists of services of technical nature, when special skills or knowledge relating to technical field are required for their provision, managerial services are rendered for performing management functions and consultancy services relate to provision of advice by som…

SPRINGER VERLAG GMBH,NEW DELHI vs. DCIT, CIRCLE- 3(1)(2), INTERNATIONAL TAXATION , NEW DELHI

In the result, the appeals of the assessee are disposed of as

ITA 434/DEL/2019[2014-15]Status: DisposedITAT Delhi23 Aug 2022AY 2014-15

Bench: Shri N.K. Billaiya & Shri N.K. Choudhry

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Shri Sanjay Kumar, Sr. DR
Section 9(1)(vi)

…fall in the category of consultancy services. Paragraphs 41 and 42 do not emanate for consideration in the present case, and effect thereof can be examined in an appropriate case [However, see Commissioner of Income Tax vs. Estel Communication P. Ltd. (2009) 318 ITR 185 (Del) and Skycell Communications Ltd. (supra)]. 25. Thus, the technical services consists of services of technical nature, when special skills or knowledge relating to technical field are required for their provision, managerial services are rendered for performing management functions and consultancy services relate to provision of advice by s…

SPRINGER VERLAG GMBH,NEW DELHI vs. ACIT, CIRCLE- 3(1)(2), INTERNATIONAL TAXATION , NEW DELHI

In the result, the appeals of the assessee are disposed of as

ITA 3826/DEL/2019[2015-16]Status: DisposedITAT Delhi23 Aug 2022AY 2015-16

Bench: Shri N.K. Billaiya & Shri N.K. Choudhry

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Shri Sanjay Kumar, Sr. DR
Section 9(1)(vi)

…fall in the category of consultancy services. Paragraphs 41 and 42 do not emanate for consideration in the present case, and effect thereof can be examined in an appropriate case [However, see Commissioner of Income Tax vs. Estel Communication P. Ltd. (2009) 318 ITR 185 (Del) and Skycell Communications Ltd. (supra)]. 25. Thus, the technical services consists of services of technical nature, when special skills or knowledge relating to technical field are required for their provision, managerial services are rendered for performing management functions and consultancy services relate to provision of advice by s…

M/S. HITACHI METGLAS (INDIA) PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 3694/DEL/2016[2011-12]Status: DisposedITAT Delhi13 Oct 2021AY 2011-12

Bench: Sh. Kul Bharatdr. B. R. R. Kumar(Through Video Conferencing) Ita No. 3694/Del/2016 : Asstt. Year : 2011-12 M/S Hitachi Metglas (India) Pvt. Ltd., Vs Dcit, (Now Merged With Hitachi Metals India Circle-11(2), Pvt. Ltd.), 1C, Vandana Building, 11, New Delhi-110002 Tolstoy Marg, Connaught Place, New Delhi-110001 (Appellant) (Respondent) Pan No. Aabch9302G Assessee By : Sh. Himanshu Sinha, Adv. Revenue By : Sh. Farhat Khan, Sr. Dr Date Of Hearing: 29.07.2021 Date Of Pronouncement: 13.10.2021

For Appellant: Sh. Himanshu Sinha, AdvFor Respondent: Sh. Farhat Khan, Sr. DR
Section 195Section 271(1)(c)Section 4Section 40Section 5Section 8Section 9(1)Section 9(1)(vii)Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘D’, NEW DELHI Before Sh. Kul Bharat, Judicial Member Dr. B. R. R. Kumar, Accountant Member (Through Video Conferencing) ITA No. 3694/Del/2016 : Asstt. Year : 2011-12 M/s Hitachi Metglas (India) Pvt. Ltd., Vs DCIT, (Now merged with Hitachi Metals India Circle-11(2), Pvt. Ltd.), 1C, Vandana Building, 11, New Delhi-110002 Tolstoy Marg, Connaught Place, New Delhi-110001 (APPELLANT) (RESPONDENT) PAN No. AABCH9302G Assessee by : Sh. Himanshu Sinha, Adv. Revenue by : Sh. Farhat Khan, Sr. DR Date of Hearing: 29.07.2021 Date of Pronouncement: 13.10.2021 ORDER Per Dr. B…

ACIT, CIRCLE- 14(1), NEW DELHI vs. KAPOOR INDUSTRIES LTD., NEW DELHI

ITA 4215/DEL/2017[2014-15]Status: DisposedITAT Delhi29 Jan 2021AY 2014-15

Bench: Shri Anil Chaturvedi & Shri Kuldip Singh

For Appellant: Shri R.K. Mehra, CAFor Respondent: Shri Shailesh Kumar, Senior DR
Section 195Section 40Section 9

…fall in the category of consultancy services. Paragraphs 41 and 42 do not emanate for consideration in the present case, and effect thereof can be examined in an appropriate case [However, see Commissioner of Income Tax vs. Estel Communication P. Ltd. (2009) 318 ITR 185 (Del) and Skycell Communications Ltd. (supra)]. 25. Thus, the technical services consists of services of technical nature, when special skills or knowledge relating to technical field are required for their provision, managerial 17 ITA No.4215/Del./2017 services are rendered for performing management functions and consultancy services relate t…

ACIT, NEW DELHI vs. M/S. KAPOOR INDUSTRIES, NEW DELHI

Accordingly the entire three grounds rose in appeal for AY 2011-12 is dismissed

ITA 4050/DEL/2015[2012-13]Status: DisposedITAT Delhi28 May 2019AY 2012-13

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Appellant: Shri R. K. Mehra, CAFor Respondent: Shri K Hauthang, Sr. DR
Section 143(3)Section 195Section 40Section 9

…rendered may possibly fall in the category of consultancy services. Paragraphs 41 and 42 do not emanate for consideration in the present case, and effect thereof can be examined in an appropriate case [However, see CIT v. Estel Communication (P.) Ltd. [2009] 318 ITR 185 (Del) and Skycell Communications Ltd. (supra)]. 25. Thus, the technical services consists of services of technical nature, when special skills or knowledge relating to technical field are required for their provision, managerial services are rendered for performing management functions and consultancy services relate to provision of advice by som…

ACIT, NEW DELHI vs. M/S. KAPOOR INDUSTRIES, NEW DELHI

Accordingly the entire three grounds rose in appeal for AY 2011-12 is dismissed

ITA 4049/DEL/2015[2011-12]Status: DisposedITAT Delhi28 May 2019AY 2011-12

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Appellant: Shri R. K. Mehra, CAFor Respondent: Shri K Hauthang, Sr. DR
Section 143(3)Section 195Section 40Section 9

…rendered may possibly fall in the category of consultancy services. Paragraphs 41 and 42 do not emanate for consideration in the present case, and effect thereof can be examined in an appropriate case [However, see CIT v. Estel Communication (P.) Ltd. [2009] 318 ITR 185 (Del) and Skycell Communications Ltd. (supra)]. 25. Thus, the technical services consists of services of technical nature, when special skills or knowledge relating to technical field are required for their provision, managerial services are rendered for performing management functions and consultancy services relate to provision of advice by som…

ITO, NEW DELHI vs. SH. KULBEER SINGH, NEW DELHI

ITA 5204/DEL/2014[2010-11]Status: DisposedITAT Delhi03 Oct 2018AY 2010-11

Bench: Shri Amit Shukla & Shri Prashant Maharishiito, Vs. Kulbeer Singh, Ward-26(1), H-432, Vikas Puri, New Delhi New Delhi Pan: Amqps5847P (Appellant) (Respondent)

For Appellant: NoneFor Respondent: Shri Amit Jain, Sr. DR
Section 143Section 195Section 197Section 40Section 9

…ax be required to be deducted at source from such payment. Various Courts and Tribunals have, in the below mentioned cases, held likewise: a. Van Oord ACZ India (P) Ltd. vs. CIT : [(2010) 323 ITR 130 (Del)] b. CIT vs. Estel Communications (P) Ltd. : [(2009) 318 ITR 185 (Del)] c. CIT vs. ICL Shipping Ltd. : [(2009) 315 ITR 195 (Mad)] d. Jindal Thermal Power Co. Ltd. vs. DCIT: [(2010) 321 ITR 31 (Kar)]. e. CIT vs. Manager, State Bank of India : [(2010) 323 ITR 93 (Raj)] f. ITO (International Taxation) vs. Prasad Production Ltd.: [(2010) 129 TTJ 641 (SB)(Chennai)] g. Mahindra & Mahindra Ltd. vs. DCIT: [(2009)…

HERO MOTOCORP LTD.,,NEW DELHI vs. ADDL.CIT, RANGE-11, NEW DELHI

In the result ground No

ITA 6990/DEL/2017[2013-14]Status: DisposedITAT Delhi20 Jun 2018AY 2013-14

Bench: Shri R. K. Panda & Ms Suchitra Kamblei.T.A. No. 6990/Del/2017 (A.Y 2013-14)

Section 143(3)Section 144C

…rendered may possibly fall in the category of consultancy services. Paragraphs 41 and 42 do not emanate for consideration in the present case, and effect thereof can be examined in an appropriate case [However, see CIT v. Estel Communication (P.) Ltd. [2009] 318 ITR 185 (Del) and Skycell Communications Ltd. (supra)].” Further Hon’ble Delhi tribunal has also explained the word ‘consultant ‘in the same decision as under as under:- “21. The word “consultant” refers to a person, who is consulted and who advises or from whom information is sought. In Black’s Law Dictionary, Eighth Edition, the word “consultation” has…

HERO MOTOCORP LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result appeal No. 2424/Del/ 2015 filed by the revenue in assessment year 2010-11 is partly allowed

ITA 1616/DEL/2017[2012-13]Status: DisposedITAT Delhi13 Jun 2018AY 2012-13

Bench: Shri R. K. Panda & Ms Suchitra Kamble

Section 143(3)Section 144CSection 92C

…rendered may possibly fall in the category of consultancy services. Paragraphs 41 and 42 do not emanate for consideration in the present case, and effect thereof can be examined in an appropriate case [However, see CIT v. Estel Communication (P.) Ltd. [2009] 318 ITR 185 (Del) and Skycell Communications Ltd. (supra)].” Further Hon’ble Delhi tribunal has also explained the word ‘consultant ‘in the same decision as under as under:- “21. The word “consultant” refers to a person, who is consulted and who advises or from whom information is sought. In Black’s Law Dictionary, Eighth Edition, the word “consultation” has…

PRINCIPAL COMMISSIONER OF INCOME TAX, DELHI-2 vs. M/S.BHARTI BT INTERNET LTD.

The appeals are allowed in the above terms

ITA/59/2018HC Delhi24 Jan 2018

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE A. K. CHAWLA

Section 194JSection 40Section 9(1)Section 9(1)(vii)

…th the view of the AO and after analysing certain provisions of the master service agreement held that the amount was not liable to tax by relying upon the decision of this Court in the case of Commissioner of Income Tax vs. Estel Communications (P) Ltd., 318 ITR 185 (Del.). In that decision, the question involved was payment of amounts on account of bandwidth allocation by overseas service provider. The Court notices that there was no privity of contract between the overseas service provider and the assessee’s subscribers; the assessee had merely retailed the services. The Revenue’s appeal…

PRINCIPAL COMMISSIONER OF INCOME TAX, DELHI-2 vs. M/S.BHARTI BT INTERNET LTD.

The appeals are allowed in the above terms

ITA/58/2018HC Delhi24 Jan 2018

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE A. K. CHAWLA

Section 194JSection 40Section 9(1)Section 9(1)(vii)

…th the view of the AO and after analysing certain provisions of the master service agreement held that the amount was not liable to tax by relying upon the decision of this Court in the case of Commissioner of Income Tax vs. Estel Communications (P) Ltd., 318 ITR 185 (Del.). In that decision, the question involved was payment of amounts on account of bandwidth allocation by overseas service provider. The Court notices that there was no privity of contract between the overseas service provider and the assessee’s subscribers; the assessee had merely retailed the services. The Revenue’s appeal…

YOU BROADBAND & CABLE INDIA LTD ( FORMERLY KNWON AS YOU TELECOM INDIA P. LTD),MUMBAI vs. DCIT 9(3), MUMBAI

In the result, appeals filed by the assessee in A

ITA 8409/MUM/2010[2006-07]Status: DisposedITAT Mumbai17 May 2017AY 2006-07

Bench: S/Shri B.R. Baskaran (Am) & Sandeep Gosain (Jm)

Section 194JSection 40Section 80

…ok support from the decision rendered by Hon’ble Madras High Court in the case of Skycell Communications Ltd and another Vs. DCIT (251 ITR 53). He further submitted that the Hon’ble Delhi Court has held in the case of CIT Vs. Estel Communications P Ltd (2009)(318 ITR 185) that the payment to non-resident for provision of bandwidth is not fee for technical services and hence the assessee is not liable to deduct tax at source. 4. On the contrary, the Ld D.R submitted that the assessee is providing internet access to its customers by procuring bandwidth from telecommunication 3 YOU Broadband & Cable India Ltd. co…

ITO (TDS), WARD-58(3), KOLKATA, KOLKATA vs. M/S. MEDIA WORLDWIDE PVT. LTD., KOLKATA

In the result, the appeal of the Revenue is dismissed

ITA 2057/KOL/2014[2011-2012]Status: DisposedITAT Kolkata12 May 2017AY 2011-2012

Bench: Shri P.M. Jagtap & Shri S.S. Viswanethra Ravi

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

…tax at source was deductible at 2% as per the provisions of section 194C. Reliance in support of this contention was placed by the assessee on the decision of the Hon’ble Delhi High Court in the case of CIT –vs.- Estel Communications Pvt. Limited reported in 318 ITR 185. The Assessing Officer, however, found the said case law relied upon by the assessee to be distinguishable on facts. According to him, the provisions of section 194C were general in nature, while the provisions of section 194J being special covering specific situation, the assessee was required to deduct tax at source at 10% instead of 2%. He, th…

DEPUTY COMMISSIONER OF INCOME TAX,, BANGALORE vs. M/S TALLY SOLUTIONS P LTD, BANGALORE

ITA 1463/BANG/2014[2009-10]Status: DisposedITAT Bangalore29 Nov 2016AY 2009-10

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Ms. Neera Malhotra, CIT(D.R)For Respondent: Shri C. Ramesh, C.A
Section 40Section 41(1)

…94J of the Act. On appeal, the CIT (Appeals) has deleted the disallowance in view of the decision of Mumbai Tribunal in the case of Pacific 27 SOT 573 as well as the decision of Hon'ble Delhi High Court in the case of CIT Vs. Estel Communications Pvt. Ltd. 318 ITR 185. 5. Before us, the learned Departmental Representative has relied upon the order of the Assessing Officer. 6. On the other hand, the learned Authorised Representative has submitted that this issue is covered by the decision of the Tribunal in the case of Pacific Internet India (supra) as well as the decision of Hon'ble (supra). 4 IT(IT)A No.14…

PRINCIPAL COMMISSIONER OF INCOME TAX - 7 vs. M/S ROHDE & SCHWARZ INDIA PVT. LTD.,

ITA/701/2016HC Delhi07 Nov 2016

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MS. JUSTICE DEEPA SHARMA

Section 40Section 9

…he assessee was under an obligation to deduct tax thereon. It was liable by virtue of Section 40(a). The disallowance by the AO was sought to be justified. The ITAT in this regard relied upon the decision of this Court in CIT vs. Estel Communications Ltd. 318 ITR 185. The question is sought to be distinguished by the Revenue on the ground that what was in issue in Estel (supra) was payment towards Internet bandwidth and whereas what is in issue in the present case is ―Frame Relay Charges‖. This Court is of the opinion that the judgment in Estel (supra) would apply because Frame Relay—according to the t…

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CIT v. Estel Communication (P.) Ltd. (318 ITR 185) — Cited in 25 Judgments | BharatTax