CIT v. Kotak Securities Ltd.

383 ITR 1Supreme Court of India2016#448 most cited

What is CIT v. Kotak Securities Ltd. authority for?

Fees for technical services under Section 9(1)(vii) can include payments for fully automated services even without direct human interface, as modern technological developments blur the specific human element in such processes.

203

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2025.

Also referred to as

CIT v. Kotak Securities Ltd. · section 9(1)(vii) · fees for technical services · FTS · automated services · human interface · section 40(a)(ia) disallowance · make available condition · DTAA · software

Also reported as

67 Taxmann.com 356239 Taxmann 139

Sections most often in play

Section 9(1)(vii)Section 143(3)Section 40(a)(ia)Section 194JSection 144C(3)Section 40(a)(i)Section 37Section 115JB

Issues it is cited on

section 194jsection 9(1)(vii)section 194hsection 40a(ia)fees for technical servicesdisallowance under section 40(a)(ia)section 92ca(1)section 9(1)section 90(2)section 9(1)(vi)section 194tested party

Judgments citing CIT v. Kotak Securities 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)

…DCIT (ITA Nos.434/Del/2019 and 3826/Del/2019)\n4. ITP Publishing India P. Ltd. vs. ACIT (ITA no. 4407/Mum/2019)\n5. DCIT vs. Campus Eai India P. Ltd. (in ITA No. 355/Del/2021)\n6. Adidas Sourcing Ltd. vs. ADIT (150 TTJ 801)\n7. CIT vs. Kotak Securities Ltd. (383 ITR 1)\n8. CIT vs. Lalitpur Power Generation Co. Ltd. (296 Taxman 372)\n\n9. Ld. Departmental Representative ('Id. DR' for short) strongly relied upon the\nobservations of Id. DRP.\n\n10. We have considered rival submissions in light of judicial precedents cited before\nus and perused the materials on record. Undoubtedly, though in course of assessment\n…

DCIT, NEW DELHI vs. M/S. VODAFONE ESSAR DIGILINK LTD., NEW DELHI

ITA 1158/DEL/2015[2010-11]Status: DisposedITAT Mumbai14 Oct 2025AY 2010-11

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI OMKARESHWAR CHIDARA (Accountant Member)

For Appellant: Shri Ketan Ved & Shri Ninad PatadeFor Respondent: Shri Pankaj Kumar
Section 143(1)Section 143(3)Section 144C(1)Section 144C(5)Section 92C

…aving expert opinion to ascertain if any human intervention was involved so as to consider the attractability or otherwise of the definition of 'technical services' under section 9(1)(vii) of the Act. In a later decision in CIT v. Kotak Securities Ltd. [2016] 383 ITR 1/239 Taxman 139/67 taxmann.com 356 (SC), the Hon'ble Supreme Court, after considering its earlier decision in Bharti Cellular Ltd. (supra), observed that: "modern day scientific and technological developments tend to blur the specific human element in an otherwise fully automated process by which such service may be provided." It was held that: 'the…

VODAFONE DIGILINK LIMITED,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME-TAX, NEW DELHI

ITA 1073/DEL/2015[2010-11]Status: DisposedITAT Mumbai14 Oct 2025AY 2010-11
Section 143(1)Section 144C(1)Section 144C(5)Section 92C

…g\nexpert opinion to ascertain if any human intervention was involved\nso as to consider the attractability or otherwise of the definition of\n'technical services' under section 9(1)(vii) of the Act. In a later\ndecision in CIT v. Kotak Securities Ltd. [2016] 383 ITR 1/239\nTaxman 139/67 taxmann.com 356 (SC), the Hon'ble Supreme Court,\nafter considering its earlier decision in Bharti Cellular Ltd. (supra),\nobserved that: \"modern day scientific and technological\ndevelopments tend to blur the specific human element in an\notherwise fully automated process by which such service may be\nprovided.\" It was held th…

FORCEPOINT INTERNATIONAL TECHNOLOGY LIMITED,NOIDA vs. ACIT, CIRCLE INT. TAXATION 1(3)(1), NEW DELHI

In the result, appeal of assessee in ITA No

ITA 976/DEL/2023[2020-21]Status: DisposedITAT Delhi22 Sept 2025AY 2020-21

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: Shri Anil Bhalla, CAFor Respondent: Shri Vijay B. Basanta CIT- DR
Section 139(1)Section 9(1)(vii)

…requires no human interface. The nature of software sold are meant for preventing cyber attack and software sold are not specific to the customer needs. 14. With reference to the decision of the Hon'ble Supreme Court in the case of Kotak Securities Limited 383 ITR 1, the ld. counsel for the assessee emphasized that law with regard to human interface remains the same. The ld. counsel for the assessee also relied on the decision of the Hon'ble Jurisdictional High Court in the case of SFDC Ireland Ltd and referred to page 483 Para 27 and the decision of the co-ordinate bench in Finastra International Financia…

ACIT, JHANDEWALAN vs. M/S MANKIND PHARMA LTD. (EARLIER KNOWN AS M/S MAGNET LABS PVT. LTD.), NEW DELHI

Accordingly, the appeal of assesse is allowed and of revenue dismissed

ITA 5141/DEL/2024[2017-18]Status: DisposedITAT Delhi27 Aug 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year: 2017-18 Acit, Vs M/S Mankind Pharma Ltd. (Earlier Circle-16(1), Known As M/S Magnet Labs Pvt. Delhi. Ltd.), 208, Okhla Industrial Estate Phase-3, Delhi – 110 020. Pan: Aaccm1861C Assessment Year: 2017-18 M/S Mankind Pharma Ltd. Vs. Acit, (Earlier Known As M/S Magnet Circle-16(1), Labs Pvt. Ltd.), Delhi 208, Okhla Industrial Estate Phase-3, Delhi – 110 020. Pan: Aaccm1861C (Appellant) (Respondent) Assessee By : Shri Gaurav Jain, Advocate & Shri Rahul Prabhakar, Advocate Revenue By : Shri Vipul Kashyap, Sr. Dr Date Of Hearing : 05.08.2025 Date Of Pronouncement : 27.08.2025 Order Per Anubhav Sharma, Jm: These Are Cross Appeals Preferred By The Revenue & The Assessee Against The Order Dated 08.08.2024 Of The Commissioner Of Income-Tax (Appeals)-30

For Appellant: Shri Gaurav Jain, Advocate &For Respondent: Shri Vipul Kashyap, Sr. DR
Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES: E : NEW DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI ANUBHAV SHARMA, JUDICIAL MEMBER Assessment Year: 2017-18 ACIT, Vs M/s Mankind Pharma Ltd. (earlier Circle-16(1), known as M/s Magnet Labs Pvt. Delhi. Ltd.), 208, Okhla Industrial Estate Phase-3, Delhi – 110 020. PAN: AACCM1861C Assessment Year: 2017-18 M/s Mankind Pharma Ltd. Vs. ACIT, (earlier known as M/s Magnet Circle-16(1), Labs Pvt. Ltd.), Delhi 208, Okhla Industrial Estate Phase-3, Delhi – 110 020. PAN: AACCM1861C (Appellant) (Respondent) Assessee by : Shri Gaurav Jain, Advocate & S…

MANKIND PHARMA LIMITED (AS SUCCESSOR OF MAGNET LABS PVT. LTD.),NEW DELHI vs. DCIT CIRCLE 16(1) DELHI, DELHI

Accordingly, the appeal of assesse is allowed and of revenue dismissed

ITA 4654/DEL/2024[2017-18]Status: DisposedITAT Delhi27 Aug 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year: 2017-18 Acit, Vs M/S Mankind Pharma Ltd. (Earlier Circle-16(1), Known As M/S Magnet Labs Pvt. Delhi. Ltd.), 208, Okhla Industrial Estate Phase-3, Delhi – 110 020. Pan: Aaccm1861C Assessment Year: 2017-18 M/S Mankind Pharma Ltd. Vs. Acit, (Earlier Known As M/S Magnet Circle-16(1), Labs Pvt. Ltd.), Delhi 208, Okhla Industrial Estate Phase-3, Delhi – 110 020. Pan: Aaccm1861C (Appellant) (Respondent) Assessee By : Shri Gaurav Jain, Advocate & Shri Rahul Prabhakar, Advocate Revenue By : Shri Vipul Kashyap, Sr. Dr Date Of Hearing : 05.08.2025 Date Of Pronouncement : 27.08.2025 Order Per Anubhav Sharma, Jm: These Are Cross Appeals Preferred By The Revenue & The Assessee Against The Order Dated 08.08.2024 Of The Commissioner Of Income-Tax (Appeals)-30

For Appellant: Shri Gaurav Jain, Advocate &For Respondent: Shri Vipul Kashyap, Sr. DR
Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES: E : NEW DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI ANUBHAV SHARMA, JUDICIAL MEMBER Assessment Year: 2017-18 ACIT, Vs M/s Mankind Pharma Ltd. (earlier Circle-16(1), known as M/s Magnet Labs Pvt. Delhi. Ltd.), 208, Okhla Industrial Estate Phase-3, Delhi – 110 020. PAN: AACCM1861C Assessment Year: 2017-18 M/s Mankind Pharma Ltd. Vs. ACIT, (earlier known as M/s Magnet Circle-16(1), Labs Pvt. Ltd.), Delhi 208, Okhla Industrial Estate Phase-3, Delhi – 110 020. PAN: AACCM1861C (Appellant) (Respondent) Assessee by : Shri Gaurav Jain, Advocate & S…

ETHIOPIAN AIRLINES GROUP ,ETHIOPIA vs. ACIT, INT. TAXATION CIRCLE-1(2)(2), DELHI

ITA 2201/DEL/2024[2017-18]Status: DisposedITAT Delhi05 Jun 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

Section 115ASection 133ASection 147Section 195Section 9(1)Section 9(1)(vii)

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘D’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER ITA Nos.2200 & 2201/Del/2024 Assessment Years: 2016-17 & 2017-18 Ethiopian Airlines Group, Vs. ACIT, Unit no. 104, 1st Windfall Intl. Taxation, Sahara Plaza, Circle-1(2)(2), Andheri Kurla Road, Delhi Mumbai PAN: AAACE1046M (Appellant) (Respondent) Assessee by Sh. Rajiv Palpuri, CA Sh. P.K. Sahu, Adv. Department by Sh. Vizay B. Vasanta, CIT(DR) Date of hearing 13.03.2025 Date of pronouncement 05.06.2025 ORDER PER SATBEER SINGH GODARA, JM These assessee’s…

DY. COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-421, MUMBAI, MUMBAI vs. SITA INFORMATION NETWORKING COMPUTING USA INC., USA

ITA 6470/MUM/2024[2016-17]Status: DisposedITAT Mumbai02 Apr 2025AY 2016-17

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Respondent: Shri Vivek Perampurna (CIT-DR) /
Section 143(3)Section 9(1)(vii)

…ot be taxed under section 9(1)(vii) for the reason that these services do not involve human element, by placing reliance on the decision of the Hon'ble Supreme Court in the case of Bharti Cellular Limited [2010] 330 ITR 239 and Kotak Securities Limited [2016] 383 ITR 1. The CIT(A) held the Passenger Services to be not taxable under Article 12 of the DTAA between India and USA also stating that no technology is made available to recipient of the services nor is there transfer of any technical knowledge, experience, skill, know-how or processes, nor does it consist of the development and transfer of a technical pla…

DY. COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-421, MUMBAI, MUMBAI vs. SITA INFORMATION NETWORKING COMPUTING USA INC., USA

ITA 6444/MUM/2024[2021-22]Status: DisposedITAT Mumbai02 Apr 2025AY 2021-22

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Respondent: Shri Vivek Perampurna (CIT-DR) /
Section 143(3)Section 9(1)(vii)

…ot be taxed under section 9(1)(vii) for the reason that these services do not involve human element, by placing reliance on the decision of the Hon'ble Supreme Court in the case of Bharti Cellular Limited [2010] 330 ITR 239 and Kotak Securities Limited [2016] 383 ITR 1. The CIT(A) held the Passenger Services to be not taxable under Article 12 of the DTAA between India and USA also stating that no technology is made available to recipient of the services nor is there transfer of any technical knowledge, experience, skill, know-how or processes, nor does it consist of the development and transfer of a technical pla…

DY. COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-421, MUMBAI, MUMBAI vs. SITA INFORMATION NETWORKING COMPUTING USA INC., USA

ITA 6443/MUM/2024[2020-21]Status: DisposedITAT Mumbai02 Apr 2025AY 2020-21

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Respondent: Shri Vivek Perampurna (CIT-DR) /
Section 143(3)Section 9(1)(vii)

…ot be taxed under section 9(1)(vii) for the reason that these services do not involve human element, by placing reliance on the decision of the Hon'ble Supreme Court in the case of Bharti Cellular Limited [2010] 330 ITR 239 and Kotak Securities Limited [2016] 383 ITR 1. The CIT(A) held the Passenger Services to be not taxable under Article 12 of the DTAA between India and USA also stating that no technology is made available to recipient of the services nor is there transfer of any technical knowledge, experience, skill, know-how or processes, nor does it consist of the development and transfer of a technical pla…

DY. COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-421, MUMBAI, MUMBAI vs. SITA INFORMATION NETWORKING COMPUTING USA INC., USA

ITA 6442/MUM/2024[2019-20]Status: DisposedITAT Mumbai02 Apr 2025AY 2019-20

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Respondent: Shri Vivek Perampurna (CIT-DR) /
Section 143(3)Section 9(1)(vii)

…ot be taxed under section 9(1)(vii) for the reason that these services do not involve human element, by placing reliance on the decision of the Hon'ble Supreme Court in the case of Bharti Cellular Limited [2010] 330 ITR 239 and Kotak Securities Limited [2016] 383 ITR 1. The CIT(A) held the Passenger Services to be not taxable under Article 12 of the DTAA between India and USA also stating that no technology is made available to recipient of the services nor is there transfer of any technical knowledge, experience, skill, know-how or processes, nor does it consist of the development and transfer of a technical pla…

DY. COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-421, MUMBAI, MUMBAI vs. SITA INFORMATION NETWORKING COMPUTING USA INC., USA

ITA 6441/MUM/2024[2018-19]Status: DisposedITAT Mumbai02 Apr 2025AY 2018-19

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Respondent: Shri Vivek Perampurna (CIT-DR) /
Section 143(3)Section 9(1)(vii)

…ot be taxed under section 9(1)(vii) for the reason that these services do not involve human element, by placing reliance on the decision of the Hon'ble Supreme Court in the case of Bharti Cellular Limited [2010] 330 ITR 239 and Kotak Securities Limited [2016] 383 ITR 1. The CIT(A) held the Passenger Services to be not taxable under Article 12 of the DTAA between India and USA also stating that no technology is made available to recipient of the services nor is there transfer of any technical knowledge, experience, skill, know-how or processes, nor does it consist of the development and transfer of a technical pla…

DY. COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-421, MUMBAI, MUMBAI vs. SITA INFORMATION NETWORKING COMPUTING USA INC., MUMBAI

ITA 6439/MUM/2024[2015-16]Status: DisposedITAT Mumbai02 Apr 2025AY 2015-16

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Respondent: Shri Vivek Perampurna (CIT-DR) /
Section 143(3)Section 9(1)(vii)

…ot be taxed under section 9(1)(vii) for the reason that these services do not involve human element, by placing reliance on the decision of the Hon'ble Supreme Court in the case of Bharti Cellular Limited [2010] 330 ITR 239 and Kotak Securities Limited [2016] 383 ITR 1. The CIT(A) held the Passenger Services to be not taxable under Article 12 of the DTAA between India and USA also stating that no technology is made available to recipient of the services nor is there transfer of any technical knowledge, experience, skill, know-how or processes, nor does it consist of the development and transfer of a technical pla…

DY. COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-421, MUMBAI, MUMBAI vs. SITA INFORMATION NETWORKING COMPUTING USA INC., USA

ITA 6436/MUM/2024[2014-15]Status: DisposedITAT Mumbai02 Apr 2025AY 2014-15

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Respondent: Shri Vivek Perampurna (CIT-DR) /
Section 143(3)Section 9(1)(vii)

…ot be taxed under section 9(1)(vii) for the reason that these services do not involve human element, by placing reliance on the decision of the Hon'ble Supreme Court in the case of Bharti Cellular Limited [2010] 330 ITR 239 and Kotak Securities Limited [2016] 383 ITR 1. The CIT(A) held the Passenger Services to be not taxable under Article 12 of the DTAA between India and USA also stating that no technology is made available to recipient of the services nor is there transfer of any technical knowledge, experience, skill, know-how or processes, nor does it consist of the development and transfer of a technical pla…

TUNGSTEN NETWORK LIMITED,UNITED KINGDOM vs. DY.COMMISSIONER OF INCOME TAX, CIVIC CENTRE, MINTO ROAD

In the result, appeal filed by the assessee is dismissed

ITA 2238/DEL/2024[2017-18]Status: DisposedITAT Delhi18 Dec 2024AY 2017-18

Bench: Shri Vimal Kumar & Shri Avdhesh Kumar Mishraita Nos. 2237 & 2238/Del/2024 (Assessment Years : 2016-17 & 2017-18) Tungsten Network Ltd. Vs. Dy. Cit Anil Saraf, No.8-2-350/3/C, Civic Centre, Road No.3, Banjara Hills, Minto Road, Hyderabad, Telangana-34 New Delhi – 110 002 Pan : Aajct 5973 F (Appellant) (Respondent) Assessee By Shri Anil Saraf, C.A. & Shri Anish Raj Saraf, C.A. Respondent By Shri Vijay B. Vasanta, Cit-D.R. Date Of Hearing 25.11.2024 Date Of Pronouncement 18.12.2024 O R D E R Per Bench :

Section 142(1)Section 144Section 144C(5)Section 147Section 148Section 9(1)(vii)

…able to tax both under the provisions of Income-tax Act and under the provisions of India-UK DTAA also. Since, all the objections of DRP were rejected the assessment order was passed. 10. Hon’ble Supreme Court in the case of Kotak Securities Ltd. reported in 383 ITR 1 (SC) has observed as under: “However, it cannot be lost sight of that modern day scientific and technological developments may tend to blur the specific human element in an otherwise fully automated process by which such services may be provided. The search for a more effective basis, therefore, must be made" -7- ITA Nos.2237 & 2238/Del/2024 Tung…

TUNGSTEN NETWORK LIMITED,UNITED KINGDOM vs. DY.COMMISSIONER OF INCOME TAX, CIVIC CENTRE, MINTO ROAD

In the result, appeal filed by the assessee is dismissed

ITA 2237/DEL/2024[2016-17]Status: DisposedITAT Delhi18 Dec 2024AY 2016-17

Bench: Shri Vimal Kumar & Shri Avdhesh Kumar Mishraita Nos. 2237 & 2238/Del/2024 (Assessment Years : 2016-17 & 2017-18) Tungsten Network Ltd. Vs. Dy. Cit Anil Saraf, No.8-2-350/3/C, Civic Centre, Road No.3, Banjara Hills, Minto Road, Hyderabad, Telangana-34 New Delhi – 110 002 Pan : Aajct 5973 F (Appellant) (Respondent) Assessee By Shri Anil Saraf, C.A. & Shri Anish Raj Saraf, C.A. Respondent By Shri Vijay B. Vasanta, Cit-D.R. Date Of Hearing 25.11.2024 Date Of Pronouncement 18.12.2024 O R D E R Per Bench :

Section 142(1)Section 144Section 144C(5)Section 147Section 148Section 9(1)(vii)

…able to tax both under the provisions of Income-tax Act and under the provisions of India-UK DTAA also. Since, all the objections of DRP were rejected the assessment order was passed. 10. Hon’ble Supreme Court in the case of Kotak Securities Ltd. reported in 383 ITR 1 (SC) has observed as under: “However, it cannot be lost sight of that modern day scientific and technological developments may tend to blur the specific human element in an otherwise fully automated process by which such services may be provided. The search for a more effective basis, therefore, must be made" -7- ITA Nos.2237 & 2238/Del/2024 Tung…

TATA TELESERVICES LTD.,NEW DELHI vs. ACIT, CIRCLE-76(1), NEW DELHI

In the result the appeal of the assessee is allowed

ITA 1057/DEL/2018[2012-13]Status: DisposedITAT Delhi11 Dec 2024AY 2012-13

Bench: Sh. M. Balaganesh & Sh. Sudhir Kumarassessment Year: 2012-13 M/S Tata Vs. Assistant Commissioner Teleserviceslimited New Of Income Tax Circle 76(1) Delhi Districtcentral Laxmi Taxation Department Nagar New Delhi 110092 M/S Tata Teleservices Limited 2A, Old Ishwar Nahar Mathura Road New Delhi 110065 (Appellant) (Respondent)

Section 191Section 194Section 194HSection 201Section 201(1)

…was the decision of the Apex Court in the case of CIT v. Bharti Cellular Ltd. [2010] 193 Taxman 97/[2011] 330 ITR 239 (SC); and the another was the decision of the Apex Court in the case of CIT v. Kotak Securities Ltd. [2016] 67 taxman.com 356/239 Taxman 139/383 ITR 1 (SC) and it was submitted if the observations made by the Apex Court in the above referred decision are considered, the decision of the Tribunal would be unsustainable and consequently, the questions may arise for consideration before this Court in the present appeals. 9. 9. We may record that in the decision of the Apex Court in the case of Bhart…

VODAFONE ESSAR MOBILE SERVICES LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeal is allowed

ITA 5146/DEL/2011[2011-12 (F.Y. 2010-11)]Status: DisposedITAT Mumbai26 Nov 2024

Bench: Shri Narendra Kumar Billaiya & Shri Rahul Chaudhary

For Appellant: RespondentFor Respondent: Shri Ketan Ved/ Ninad Patade
Section 194Section 194HSection 194JSection 9(1)(vii)

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “J” BENCH, MUMBAI BEFORE SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER AND SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER ITA No.5142/D/2011 Assessment Year: 2003-04 ITA No.5146/D/2011 Assessment Year: 2011-12 Vodafone Mobile Assistant Commissioner Services Limited of Income Tax Circle c-45, 51(1) Okhla Indusrial Area, Vs. Aayakar Bhawan, Phase II, New Delhi- 110020 Distt. Centre, PAN: AAACS4457Q Laxmi Nagar, Appellant : Respondent New Delhi. ITA No.5143/D/2011 Assessment Year: 2008-09 ITA No.5144/D/2011 Assessment Year: 2009-10 ITA No.5145/D/2011 Assessment Year: 2010-11…

VODAFONE ESSAR MOBILE SERVICES LTD.,NEW DELHI vs. JCIT, NEW DELHI

In the result, the appeal is partly allowed

ITA 5145/DEL/2011[2010-11 (F.Y. 2009-10)]Status: DisposedITAT Mumbai26 Nov 2024
For Appellant: RespondentFor Respondent: Ms. Vatsala Jha (PCIT)
Section 194Section 194HSection 194JSection 9(1)(vii)

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “J” BENCH, MUMBAI BEFORE SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER AND SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER ITA No.5142/D/2011 Assessment Year: 2003-04 ITA No.5146/D/2011 Assessment Year: 2011-12 Vodafone Mobile Assistant Commissioner Services Limited of Income Tax Circle c-45, 51(1) Okhla Indusrial Area, Vs. Aayakar Bhawan, Phase II, Distt. Centre, New Delhi- 110020 Laxmi Nagar, PAN: AAACS4457Q New Delhi. Appellant : Respondent ITA No.5143/D/2011 Assessment Year: 2008-09 ITA No.5144/D/2011 Assessment Year: 2009-10 ITA No.5145/D/2011 Assessment Year: 2010-11 Voda…

VODAFONE ESSAR MOBILE SERVICES LTD.,NEW DELHI vs. JCIT, NEW DELHI

ITA 5144/DEL/2011[2009-10 (F.Y. 2008-09)]Status: DisposedITAT Mumbai26 Nov 2024

Bench: Shri Narendra Kumar Billaiya & Shri Rahul Chaudhary

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

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “J” BENCH, MUMBAI BEFORE SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER AND SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER ITA No.5142/D/2011 Assessment Year: 2003-04 ITA No.5146/D/2011 Assessment Year: 2011-12 Vodafone Services Limited c-45, Okhla Indusrial Area, Vs. Phase II, New Delhi- 110020 PAN: AAACS4457Q Mobile Assistant Commissioner of Income Tax Circle 51(1) Aayakar Bhawan, Distt. Centre, Laxmi Nagar, New Delhi. Respondent Appellant ITA No.5143/D/2011 Assessment Year: 2008-09 ITA No.5144/D/2011 Assessment Year: 2009-10 ITA No.5145/D/2011 Assessment Year: 2010-11 V…

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