Hindustan Coca Cola v. CIT

402 ITR 539High Court2018#1555 most cited

What is Hindustan Coca Cola v. CIT authority for?

Section 194H of the Income-tax Act is not applicable to discounts extended by a principal to its distributors, as such discounts are not considered commission or brokerage liable for TDS.

73

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2018 to 2025.

Also referred to as

Hindustan Coca Cola v. CIT · Section 194H · TDS on discount to distributors · discount not commission · principal agent relationship · applicability of Section 194H · no TDS on trade discount · distributor discount

Sections most often in play

Section 40(a)(ia)Section 194HSection 35ABBSection 271(1)(c)Section 143(3)Section 35ABASection 37(1)Section 263

Issues it is cited on

section 35abbsection 272bbbsection 271bbsection 272aasection 271fbsection 272bbsection 271casection 194hsection 272bsection 271basection 271fasection 115o

Judgments citing Hindustan Coca Cola v. CIT

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

…High Court referred supra had been considered and distinguished by the Hon'ble Karnataka High Court referred supra. 2.8.4. We further find that the Hon'ble Rajasthan High Court in the case of Hindustan Coca Cola Beverages (P) Ltd vs CIT III Jaipur reported in 402 ITR 539 (Raj) which had rendered a comprehensive judgement on the impugned issue together with various other assesses including Idea Cellular Ltd (assessee herein). The relevant Income Tax Appeal Nos. 168/2015, 169/2015, 170/2015 and 171/2015 which were admitted by the Hon'ble Rajasthan High Court on 18/10/2016 relates to assessee herein for Rajasthan Ci…

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

…t referred supra had been considered and\ndistinguished by the Hon'ble Karnataka High Court referred supra.\n\n2. 8. 4. We further find that the Hon'ble Rajasthan High Court in\nthe case of Hindustan Coca Cola Beverages (P) Ltd vs CIT III\nJaipur reported in 402 ITR 539 (Raj) which had rendered a\ncomprehensive judgement on the impugned issue together with\nvarious other assesses including Idea Cellular Ltd (assessee\nherein). The relevant Income Tax Appeal Nos.168/2015,\n169/2015, 170/2015 and 171/2015 which were admitted by the\nHon'ble Rajasthan High Court on 18/10/2016 relates to assessee\nherein for Rajasth…

ACIT CIRCLE 25(1) , DELHI vs. TATA TELESERVICES LTD. , DELHI

Accordingly, this issue is raised in grounds of appeal No.4 of the Revenue in all these years is dismissed

ITA 17/DEL/2022[2016-17]Status: DisposedITAT Delhi26 Aug 2025AY 2016-17

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.5665/Del/2019 (Assessment Year 2012-13)

Section 37(1)

….3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in not following the order passed by Hon'ble Rajasthan and Karnataka High Court in the Appellant's own case, reported as Hindustan Coca Cola Beverages (P) Ltd v. CIT [2017] 402 ITR 539 and Bharti Airtel Ltd. v. DCIT [2015] 372 ITR 33 respectively. wherein it was categorically held that provisions of section 194H of the Act are not applicable on the discount extended to distributors. Further, learned CIT(A) has erred in relying on the decision passed by the Hon'ble Delhi High Court, reported as CIT vs. Idea Cellular Ltd. (2010)…

TATA TELESERVICES LTD.,NEW DELHI vs. DCIT, CIRCLE-25(1), NEW DELHI

Accordingly, this issue is raised in grounds of appeal No.4 of the Revenue in all these years is dismissed

ITA 337/DEL/2021[2016-17]Status: DisposedITAT Delhi26 Aug 2025AY 2016-17

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.5665/Del/2019 (Assessment Year 2012-13)

Section 37(1)

….3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in not following the order passed by Hon'ble Rajasthan and Karnataka High Court in the Appellant's own case, reported as Hindustan Coca Cola Beverages (P) Ltd v. CIT [2017] 402 ITR 539 and Bharti Airtel Ltd. v. DCIT [2015] 372 ITR 33 respectively. wherein it was categorically held that provisions of section 194H of the Act are not applicable on the discount extended to distributors. Further, learned CIT(A) has erred in relying on the decision passed by the Hon'ble Delhi High Court, reported as CIT vs. Idea Cellular Ltd. (2010)…

DCIT CIRCLE 25(1), NEW DELHI vs. TATA TELESERVICES LTD., NEW DELHI

Accordingly, this issue is raised in grounds of appeal No.4 of the Revenue in all these years is dismissed

ITA 5927/DEL/2019[2015-16]Status: DisposedITAT Delhi26 Aug 2025AY 2015-16

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.5665/Del/2019 (Assessment Year 2012-13)

Section 37(1)

….3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in not following the order passed by Hon'ble Rajasthan and Karnataka High Court in the Appellant's own case, reported as Hindustan Coca Cola Beverages (P) Ltd v. CIT [2017] 402 ITR 539 and Bharti Airtel Ltd. v. DCIT [2015] 372 ITR 33 respectively. wherein it was categorically held that provisions of section 194H of the Act are not applicable on the discount extended to distributors. Further, learned CIT(A) has erred in relying on the decision passed by the Hon'ble Delhi High Court, reported as CIT vs. Idea Cellular Ltd. (2010)…

DCIT CIRCLE 25(1), NEW DELHI vs. TATA TELESERVICES LTD., NEW DELHI

Accordingly, this issue is raised in grounds of appeal No.4 of the Revenue in all these years is dismissed

ITA 5926/DEL/2019[2014-15]Status: DisposedITAT Delhi26 Aug 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.5665/Del/2019 (Assessment Year 2012-13)

Section 37(1)

….3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in not following the order passed by Hon'ble Rajasthan and Karnataka High Court in the Appellant's own case, reported as Hindustan Coca Cola Beverages (P) Ltd v. CIT [2017] 402 ITR 539 and Bharti Airtel Ltd. v. DCIT [2015] 372 ITR 33 respectively. wherein it was categorically held that provisions of section 194H of the Act are not applicable on the discount extended to distributors. Further, learned CIT(A) has erred in relying on the decision passed by the Hon'ble Delhi High Court, reported as CIT vs. Idea Cellular Ltd. (2010)…

DCIT CIRCLE - 25(1), NEW DELHI vs. TATA TELESERVICES LTD.,, NEW DELHI

Accordingly, this issue is raised in grounds of appeal No.4 of the Revenue in all these years is dismissed

ITA 5925/DEL/2019[2013-14]Status: DisposedITAT Delhi26 Aug 2025AY 2013-14

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.5665/Del/2019 (Assessment Year 2012-13)

Section 37(1)

….3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in not following the order passed by Hon'ble Rajasthan and Karnataka High Court in the Appellant's own case, reported as Hindustan Coca Cola Beverages (P) Ltd v. CIT [2017] 402 ITR 539 and Bharti Airtel Ltd. v. DCIT [2015] 372 ITR 33 respectively. wherein it was categorically held that provisions of section 194H of the Act are not applicable on the discount extended to distributors. Further, learned CIT(A) has erred in relying on the decision passed by the Hon'ble Delhi High Court, reported as CIT vs. Idea Cellular Ltd. (2010)…

DCIT CIRCLE - 25(1), NEW DELHI vs. TATA TELESERVICES LTD.,, NEW DELHI

Accordingly, this issue is raised in grounds of appeal No.4 of the Revenue in all these years is dismissed

ITA 5924/DEL/2019[2012-13]Status: DisposedITAT Delhi26 Aug 2025AY 2012-13

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.5665/Del/2019 (Assessment Year 2012-13)

Section 37(1)

….3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in not following the order passed by Hon'ble Rajasthan and Karnataka High Court in the Appellant's own case, reported as Hindustan Coca Cola Beverages (P) Ltd v. CIT [2017] 402 ITR 539 and Bharti Airtel Ltd. v. DCIT [2015] 372 ITR 33 respectively. wherein it was categorically held that provisions of section 194H of the Act are not applicable on the discount extended to distributors. Further, learned CIT(A) has erred in relying on the decision passed by the Hon'ble Delhi High Court, reported as CIT vs. Idea Cellular Ltd. (2010)…

TATA TELESERVICES LTD.,,NEW DELHI vs. ACIT CIRCLE - 25(1), NEW DELHI

Accordingly, this issue is raised in grounds of appeal No.4 of the Revenue in all these years is dismissed

ITA 5666/DEL/2019[2013-14]Status: DisposedITAT Delhi26 Aug 2025AY 2013-14

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.5665/Del/2019 (Assessment Year 2012-13)

Section 37(1)

….3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in not following the order passed by Hon'ble Rajasthan and Karnataka High Court in the Appellant's own case, reported as Hindustan Coca Cola Beverages (P) Ltd v. CIT [2017] 402 ITR 539 and Bharti Airtel Ltd. v. DCIT [2015] 372 ITR 33 respectively. wherein it was categorically held that provisions of section 194H of the Act are not applicable on the discount extended to distributors. Further, learned CIT(A) has erred in relying on the decision passed by the Hon'ble Delhi High Court, reported as CIT vs. Idea Cellular Ltd. (2010)…

TATA TELESERVICES LTD.,,NEW DELHI vs. ACIT CIRCLE - 25(1), NEW DELHI

Accordingly, this issue is raised in grounds of appeal No.4 of the Revenue in all these years is dismissed

ITA 5665/DEL/2019[2012-13]Status: DisposedITAT Delhi26 Aug 2025AY 2012-13

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.5665/Del/2019 (Assessment Year 2012-13)

Section 37(1)

….3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in not following the order passed by Hon'ble Rajasthan and Karnataka High Court in the Appellant's own case, reported as Hindustan Coca Cola Beverages (P) Ltd v. CIT [2017] 402 ITR 539 and Bharti Airtel Ltd. v. DCIT [2015] 372 ITR 33 respectively. wherein it was categorically held that provisions of section 194H of the Act are not applicable on the discount extended to distributors. Further, learned CIT(A) has erred in relying on the decision passed by the Hon'ble Delhi High Court, reported as CIT vs. Idea Cellular Ltd. (2010)…

TATA TELESERVICES LTD.,NOIDA vs. ACIT, CIRCLE- 25(1), NEW DELHI

Accordingly, this issue is raised in grounds of appeal No.4 of the Revenue in all these years is dismissed

ITA 4150/DEL/2017[2011-12]Status: DisposedITAT Delhi26 Aug 2025AY 2011-12

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.5665/Del/2019 (Assessment Year 2012-13)

Section 37(1)

….3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in not following the order passed by Hon'ble Rajasthan and Karnataka High Court in the Appellant's own case, reported as Hindustan Coca Cola Beverages (P) Ltd v. CIT [2017] 402 ITR 539 and Bharti Airtel Ltd. v. DCIT [2015] 372 ITR 33 respectively. wherein it was categorically held that provisions of section 194H of the Act are not applicable on the discount extended to distributors. Further, learned CIT(A) has erred in relying on the decision passed by the Hon'ble Delhi High Court, reported as CIT vs. Idea Cellular Ltd. (2010)…

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1, JODHPUR , JODHPUR vs. JODHPUR HEALTHCARE PVT. LTD., JODHPUR

In the result, the revenue appeals in ITA Nos

ITA 545/JODH/2024[2018-19]Status: DisposedITAT Jodhpur26 Jun 2025AY 2018-19

Bench: Dr. Mitha Lal Meena, Hon'Ble & Anikesh Banerjee, Hon'Ble

Section 139Section 148Section 35ASection 801A(7)Section 80J

…d upon. Looking to the volume of business being carried in the very initial year, such discount allowed merits acceptance and also referred to the decision of Hon'ble Rajasthan High Court in the case of Hindustan Coca Cola Beverages vs. CIT reported in (2018) 402 ITR 539 (Raj) in which it was held that in a competitive world to grow the business, if such expenses are incurred the same cannot be disallowed. Similarly in the case of CIT vs. Devayhi Beverages Ltd. reported in (2008) 296 ITR 41 (Del) it was held that the Tribunal has rightly noted that the CIT(A) could not assume the role of the assessee and decide w…

ASSTT. COMMISSIONER OF INCOME-TAX, CIRCLE-1, JODHPUR , JODHPUR vs. JODHPUR HEALTHCARE PVT. LTD., JODHPUR

In the result, the revenue appeals in ITA Nos

ITA 544/JODH/2024[2017-18]Status: DisposedITAT Jodhpur26 Jun 2025AY 2017-18

Bench: Dr. Mitha Lal Meena, Hon'Ble & Anikesh Banerjee, Hon'Ble

Section 139Section 148Section 35ASection 801A(7)Section 80J

…d upon. Looking to the volume of business being carried in the very initial year, such discount allowed merits acceptance and also referred to the decision of Hon'ble Rajasthan High Court in the case of Hindustan Coca Cola Beverages vs. CIT reported in (2018) 402 ITR 539 (Raj) in which it was held that in a competitive world to grow the business, if such expenses are incurred the same cannot be disallowed. Similarly in the case of CIT vs. Devayhi Beverages Ltd. reported in (2008) 296 ITR 41 (Del) it was held that the Tribunal has rightly noted that the CIT(A) could not assume the role of the assessee and decide w…

ASSTT. COMMISSIONER OF INCOME-TAX, CIRCLE-1, JODHPUR , JODHPUR vs. JODHPUR HEALTHCARE PVT. LTD., JODHPUR

In the result, the revenue appeals in ITA Nos

ITA 541/JODH/2024[2016-17]Status: DisposedITAT Jodhpur26 Jun 2025AY 2016-17

Bench: Dr. Mitha Lal Meena, Hon'Ble & Anikesh Banerjee, Hon'Ble

Section 139Section 148Section 35ASection 801A(7)Section 80J

…d upon. Looking to the volume of business being carried in the very initial year, such discount allowed merits acceptance and also referred to the decision of Hon'ble Rajasthan High Court in the case of Hindustan Coca Cola Beverages vs. CIT reported in (2018) 402 ITR 539 (Raj) in which it was held that in a competitive world to grow the business, if such expenses are incurred the same cannot be disallowed. Similarly in the case of CIT vs. Devayhi Beverages Ltd. reported in (2008) 296 ITR 41 (Del) it was held that the Tribunal has rightly noted that the CIT(A) could not assume the role of the assessee and decide w…

VODAFONE MOBILE SERVICES LTD.(FORMERLY KNOWN AS VODAFONE DIGILINK LTD WHICH MERGED WITH VODAFONE MOBILE SERVICES LTD.),NEW DELHI vs. DCIT, CIRCLE-26(2), NEW DELHI

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 4189/DEL/2017[2007-08]Status: DisposedITAT Mumbai22 May 2025AY 2007-08

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2007-08 Vodafone Mobile Services Limited Deputy Commissioner Of (Formerly Known As Vodafone Income Tax, Circle 26(2), Digilink Ltd Which Stands Vs. New Delhi Amalgamated With Vodafone Mobile (Jurisdiction Realigned From Service Limited) Circle 17(1), New Delhi) C-48, Phase-Ii, Okhla Industrial Area, New Delhi- 110020. Pan No. Aaaca 3202 D Appellant Respondent

For Appellant: Mr. Ketan VedFor Respondent: Mr. Pankaj Kumar, Sr. DR
Section 115Section 115JSection 143(3)Section 194HSection 37(1)Section 40Section 43(1)

…High Court referred supra had been considered and distinguished by the Hon'ble Karnataka High Court referred supra. 2.8.4. We further find that the Hon'ble Rajasthan High Court in the case of Hindustan Coca Cola Beverages (P) Ltd vs CIT III Jaipur reported in 402 ITR 539 (Raj) which had rendered a comprehensive judgement on the impugned issue together with various other assesses including Idea Cellular Ltd (assessee herein). The relevant Income Tax Appeal Nos. 168/2015, 169/2015, 170/2015 and 171/2015 which were admitted by the Hon'ble Rajasthan High Court on 18/10/2016 relates to assessee herein for Rajasthan Ci…

VODAFONE IDEA LIMITED (EARLIER KNOWN AS VODAFONE INDIA LTD. WHICH STANDS MERGED WITH IDEA CELLULAR LTD. AND CONSEQUENTLY KNOWN AS IDEA LTD.),MUMBAI vs. ACIT - CIRCLE- 5 (3)(2), MUMBAI

Appeal are allowed for statistical purposes

ITA 316/MUM/2019[2014-15]Status: DisposedITAT Mumbai18 Feb 2025AY 2014-15

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ketan Ved; Shri Ninad PatadeFor Respondent: Date
Section 115JSection 143(3)Section 144CSection 144C(13)Section 144C(5)Section 14ASection 194HSection 32(1)Section 40Section 92C

…igh Court referred supra had been considered and distinguished by the Hon'ble Karnataka High Court referred supra. 2.8.4. We further find that the Hon'ble Rajasthan High Court in the case of Hindustan Coca Cola Beverages (P) Ltd vs CIT III Jaipur reported in 402 ITR 539 (Raj) which had rendered a comprehensive judgement on the impugned issue together with various other assesses including Idea Cellular Ltd (assessee herein). The relevant Income Tax Appeal Nos. 168/2015, 169/2015, 170/2015 and 171/2015 which were admitted by the Hon'ble Rajasthan High Court on 18/10/2016 relates to assessee herein for Rajasthan Ci…

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)

…High Court referred supra had been considered and distinguished by the Hon'ble Karnataka High Court referred supra. 2.8.4. We further find that the Hon'ble Rajasthan High Court in the case of Hindustan Coca Cola Beverages (P) Ltd vs CIT III Jaipur reported in 402 ITR 539 (Raj) which had rendered a comprehensive judgement on the impugned issue together with various other assesses including Idea Cellular Ltd (assessee herein). The relevant Incоте Тах Appeal Nos. 168/2015, 169/2015, 170/2015 and 171/2015 which were admitted by the Hon'ble Rajasthan High Court on 18/10/2016 relates to assessee herein for Rajasthan Ci…

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

In the result, the appeal is partly allowed

ITA 5143/DEL/2011[2008-09 (F.Y.-2007-08)]Status: DisposedITAT Mumbai26 Nov 2024

Bench: Shri Narendra Kumar Billaiya & Shri Rahul Chaudharyassessment Year: 2003-04 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 Assessment Year: 2008-09 Assessment Year: 2009-10 Assessment Year: 2010-11 Vodafone Mobile Joint Commissioner Of Services Limited Income Tax Circle 51(1) C-45, Aayakar Bhawan, Okhla Indusrial Area, Vs. Distt. Centre, Phase Ii, Laxmi Nagar, New Delhi- 110020 New Delhi. Pan: Aaacs4457Q Appellant : Respondent

For Appellant: RespondentFor Respondent: Ms. Vatsala Jha (PCIT)
Section 194Section 194HSection 194JSection 9(1)(vii)

…e Mobile Services Limited had been considered and distinguished by the Hon'ble Karnataka High Court referred supra. 2.8.4. We further find that the Hon'ble Rajasthan High Court in the case of Hindustan Coca Cola Beverages (P) Ltd vs CIT III Jaipur reported in 402 ITR 539 (Raj) which had rendered a comprehensive judgement on the impugned issue together with various other assesses including Idea Cellular Ltd (assessee herein). The relevant Income Tax Appeal Nos. 168/2015, 169/2015, 170/2015 and 171/2015 which were admitted by the Hon'ble Rajasthan High Court on 18/10/2016 relates to assessee herein for Rajasthan Ci…

VODAFONE INDIA LTD,MUMBAI vs. DCIT 8(3)(2), MUMBAI

Appeal are allowed for statistical purposes

ITA 6671/MUM/2017[2013-14]Status: DisposedITAT Mumbai22 Oct 2024AY 2013-14

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ketan VedFor Respondent: Date
Section 115JSection 143(3)Section 144CSection 144C(13)Section 144C(5)Section 14ASection 32Section 32(1)Section 35ASection 40

…High Court referred supra had been considered and distinguished by the Hon'ble Karnataka High Court referred supra. 2.8.4. We further find that the Hon'ble Rajasthan High Court in the case of Hindustan Coca Cola Beverages (P) Ltd vs CIT III Jaipur reported in 402 ITR 539 (Raj) which had rendered a comprehensive judgement on the impugned issue together with various other assesses including Idea Cellular Ltd (assessee herein). The relevant Income Tax Appeal Nos. 168/2015, 169/2015, 170/2015 and 171/2015 which were admitted by the Hon'ble Rajasthan High Court on 18/10/2016 relates to assessee herein for Rajasthan Ci…

M/S. IDEA CELLUAR LTD.,INDORE vs. THE ITO (TDS)-II, INDORE

In the result, the appeal of assessee is allowed for statistical purposes

ITA 758/IND/2013[2010-11]Status: DisposedITAT Indore22 Nov 2023AY 2010-11

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S. Vodafone Idea Ltd. Ito (Tds)-Ii (Formerly Known As M/S. Indore Idea Cellular Ltd.) Vs. 139-140 Electronics Complex Pardeshipura, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaacb 2100P Assessee By Shri Sumit Nema, Sr. Adv. & Shri Gagan Tiwari, Adv Revenue By Ms. Simran Bhullar, Cit-Dr Date Of Hearing 21.11.2023 Date Of Pronouncement 22.11.2023

Section 194HSection 201Section 201(1)

…ls of the decisions given divergent views in favour of the assessee and revenue are as under: In favour of assessee: i. Bharati Airtel Ltd. vs. DCIT, 52 taxmann.com 31 (Kar) ii. CIT vs. Vodafone Cellular (ITANo.1152/2017 (Bom) iii. Hindustan Coca Cola vs. CIT 402 ITR 539 (SC) In favour of Revenue : i. ACIT vs. Bharati Cellular Ltd. 105 ITD 129 ii. CIT vs. Idea Cellular Ltd. 189 taxmann.com 118 (Del) iii. Vodafone Essar Cellular vs. ACIT 194 taxman 518(Ker) iv. Bharati Cellular Ltd. Vs. ACIT reported 12 taxmann.com 30(Cal) Page 5 of 8 Idea Cellular Ltd.. Page 6 of 8 8. Apart from these judgments of the Hon’ble Hig…

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Hindustan Coca Cola v. CIT (402 ITR 539) — Cited in 73 Judgments | BharatTax