Sodex SVC India (P) Ltd. v. DCIT (TDS) 2(2)

92 Taxmann.com 260Income Tax Appellate Tribunal2018#1324 most cited

What is Sodex SVC India (P) Ltd. v. DCIT (TDS) 2(2) authority for?

A statutory provision is not construed to have retrospective operation unless such a construction is explicitly stated in the Act or arises by necessary and distinct implication.

86

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2019 to 2024.

Also referred to as

Sodexo SVC India · Section 153 · Section 194C · Section 194I · Section 194J · Section 200 · Section 201 · retrospective operation · statutory interpretation · ITAT

Sections most often in play

Section 153Section 194CSection 194ISection 194JSection 200Section 201Section 201(1)Section 201(1A)

Judgments citing Sodex SVC India (P) Ltd. v. DCIT (TDS) 2(2)

DCIT, LAXMINAGAR vs. TURNER GENERAL ENTERTAINMENT NETWORKS INDIA PRIVATE LIMITED, MAHIPALPUR DELHI

In the result, assessee's appeal is partly

ITA 473/DEL/2024[2011-12]Status: DisposedITAT Delhi14 Nov 2024AY 2011-12

Bench: Sh. M. Balaganesh & Sh. Sudhir Kumarassessment Year: 2011-12 Dcit Vs Turner General Laxmi Nagar Entertainment Net Works New Delhi India Limited Mahipalpur Delhi Tan No. Deln08096E (Appellant) (Respondent)

Section 201Section 201(1)Section 201(3)Section 271CSection 3

…1 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘H’, NEW DELHI BEFORE SH. M. BALAGANESH, ACCOUNTANT MEMBER AND SH. SUDHIR KUMAR, JUDICIAL MEMBER Assessment Year: 2011-12 DCIT Vs Turner General Laxmi Nagar Entertainment Net works New Delhi India Limited Mahipalpur Delhi TAN No. DELN08096E (APPELLANT) (RESPONDENT) Appellants by Sh. Pravin Rawal, CIT DR Respondent by Sh.Manuj Sabharwal Advocate Sh.Druna Negi, Advocate Sh. Devvat Tiwari Advocate Date of hearing: 14/10/2024 Date of Pronouncement: 14/11/2024 ORDER PER SUDHIR KUMAR, JM: This appeal by the revenue is directed against the order of the Commissio…

M/S. LIFE INSURANCE CORPORATION OF INDIA,CHITRADURGA vs. THE INCOME TAX OFFICER (TDS) - WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 566/BANG/2020[2016-17]Status: DisposedITAT Bangalore21 Jan 2021AY 2016-17

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…ration unless such a construction appears very clearly in the terms of the Act, or arises by necessary and distinct implication. 6.2.10. This view is supported by following decisions: • Hon’ble ITAT Mumbai in case of Sodexo SVC India Pvt.Ltd reported in (2018 92 Taxmann.com 260 • ACIT vs.Acer India Pvt.Ltd in ITA No. 2570 to 2572/Bang/2017 for assessment year 2009-10 to 2011- 12 by order dated 14/09/2019. 6.2.11. Hon'ble Gujarat High Court, in case of Tata Teleservices vs.UOI reported in (2016) 385 ITR 497, on identical issue extensively dealt on the issue of retrospective applicability of the provisions by apply…

M/S. LIFE INSURANCE CORPORATION OF INDIA,CHITRADURGA vs. THE INCOME TAX OFFICER (TDS) - WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 565/BANG/2020[2016-17]Status: DisposedITAT Bangalore21 Jan 2021AY 2016-17

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…ration unless such a construction appears very clearly in the terms of the Act, or arises by necessary and distinct implication. 6.2.10. This view is supported by following decisions: • Hon’ble ITAT Mumbai in case of Sodexo SVC India Pvt.Ltd reported in (2018 92 Taxmann.com 260 • ACIT vs.Acer India Pvt.Ltd in ITA No. 2570 to 2572/Bang/2017 for assessment year 2009-10 to 2011- 12 by order dated 14/09/2019. 6.2.11. Hon'ble Gujarat High Court, in case of Tata Teleservices vs.UOI reported in (2016) 385 ITR 497, on identical issue extensively dealt on the issue of retrospective applicability of the provisions by apply…

M/S. LIFE INSURANCE CORPORATION OF INDIA,CHITRADURGA vs. THE INCOME TAX OFFICER (TDS) - WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 564/BANG/2020[2015-16]Status: DisposedITAT Bangalore21 Jan 2021AY 2015-16

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…ration unless such a construction appears very clearly in the terms of the Act, or arises by necessary and distinct implication. 6.2.10. This view is supported by following decisions: • Hon’ble ITAT Mumbai in case of Sodexo SVC India Pvt.Ltd reported in (2018 92 Taxmann.com 260 • ACIT vs.Acer India Pvt.Ltd in ITA No. 2570 to 2572/Bang/2017 for assessment year 2009-10 to 2011- 12 by order dated 14/09/2019. 6.2.11. Hon'ble Gujarat High Court, in case of Tata Teleservices vs.UOI reported in (2016) 385 ITR 497, on identical issue extensively dealt on the issue of retrospective applicability of the provisions by apply…

M/S. LIFE INSURANCE CORPORATION OF INDIA,CHITRADURGA vs. THE INCOME TAX OFFICER (TDS) - WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 563/BANG/2020[2015-16]Status: DisposedITAT Bangalore21 Jan 2021AY 2015-16

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…ration unless such a construction appears very clearly in the terms of the Act, or arises by necessary and distinct implication. 6.2.10. This view is supported by following decisions: • Hon’ble ITAT Mumbai in case of Sodexo SVC India Pvt.Ltd reported in (2018 92 Taxmann.com 260 • ACIT vs.Acer India Pvt.Ltd in ITA No. 2570 to 2572/Bang/2017 for assessment year 2009-10 to 2011- 12 by order dated 14/09/2019. 6.2.11. Hon'ble Gujarat High Court, in case of Tata Teleservices vs.UOI reported in (2016) 385 ITR 497, on identical issue extensively dealt on the issue of retrospective applicability of the provisions by apply…

M/S. LIFE INSURANCE CORPORATION OF INDIA,CHITRADURGA vs. THE INCOME TAX OFFICER (TDS) - WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 562/BANG/2020[2014-15]Status: DisposedITAT Bangalore21 Jan 2021AY 2014-15

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…ration unless such a construction appears very clearly in the terms of the Act, or arises by necessary and distinct implication. 6.2.10. This view is supported by following decisions: • Hon’ble ITAT Mumbai in case of Sodexo SVC India Pvt.Ltd reported in (2018 92 Taxmann.com 260 • ACIT vs.Acer India Pvt.Ltd in ITA No. 2570 to 2572/Bang/2017 for assessment year 2009-10 to 2011- 12 by order dated 14/09/2019. 6.2.11. Hon'ble Gujarat High Court, in case of Tata Teleservices vs.UOI reported in (2016) 385 ITR 497, on identical issue extensively dealt on the issue of retrospective applicability of the provisions by apply…

M/S. LIFE INSURANCE CORPORATION OF INDIA,CHITRADURGA vs. THE INCOME TAX OFFICER (TDS) - WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 561/BANG/2020[2014-15]Status: DisposedITAT Bangalore21 Jan 2021AY 2014-15

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…ration unless such a construction appears very clearly in the terms of the Act, or arises by necessary and distinct implication. 6.2.10. This view is supported by following decisions: • Hon’ble ITAT Mumbai in case of Sodexo SVC India Pvt.Ltd reported in (2018 92 Taxmann.com 260 • ACIT vs.Acer India Pvt.Ltd in ITA No. 2570 to 2572/Bang/2017 for assessment year 2009-10 to 2011- 12 by order dated 14/09/2019. 6.2.11. Hon'ble Gujarat High Court, in case of Tata Teleservices vs.UOI reported in (2016) 385 ITR 497, on identical issue extensively dealt on the issue of retrospective applicability of the provisions by apply…

M/S LIFE INSURANCE CORPORATION OF INDIA,CHITRADURGA vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 560/BANG/2020[2013-14]Status: DisposedITAT Bangalore21 Jan 2021AY 2013-14

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…ration unless such a construction appears very clearly in the terms of the Act, or arises by necessary and distinct implication. 6.2.10. This view is supported by following decisions: • Hon’ble ITAT Mumbai in case of Sodexo SVC India Pvt.Ltd reported in (2018 92 Taxmann.com 260 • ACIT vs.Acer India Pvt.Ltd in ITA No. 2570 to 2572/Bang/2017 for assessment year 2009-10 to 2011- 12 by order dated 14/09/2019. 6.2.11. Hon'ble Gujarat High Court, in case of Tata Teleservices vs.UOI reported in (2016) 385 ITR 497, on identical issue extensively dealt on the issue of retrospective applicability of the provisions by apply…

M/S LIFE INSURANCE CORPORATION OF INDIA,CHITRADURGA vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 559/BANG/2020[2013-14]Status: DisposedITAT Bangalore21 Jan 2021AY 2013-14

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…ration unless such a construction appears very clearly in the terms of the Act, or arises by necessary and distinct implication. 6.2.10. This view is supported by following decisions: • Hon’ble ITAT Mumbai in case of Sodexo SVC India Pvt.Ltd reported in (2018 92 Taxmann.com 260 • ACIT vs.Acer India Pvt.Ltd in ITA No. 2570 to 2572/Bang/2017 for assessment year 2009-10 to 2011- 12 by order dated 14/09/2019. 6.2.11. Hon'ble Gujarat High Court, in case of Tata Teleservices vs.UOI reported in (2016) 385 ITR 497, on identical issue extensively dealt on the issue of retrospective applicability of the provisions by apply…

M/S LIFE INSURANCE CORPORATION OF INDIA,CHITRADURGA vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 558/BANG/2020[2012-13]Status: DisposedITAT Bangalore21 Jan 2021AY 2012-13

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…ration unless such a construction appears very clearly in the terms of the Act, or arises by necessary and distinct implication. 6.2.10. This view is supported by following decisions: • Hon’ble ITAT Mumbai in case of Sodexo SVC India Pvt.Ltd reported in (2018 92 Taxmann.com 260 • ACIT vs.Acer India Pvt.Ltd in ITA No. 2570 to 2572/Bang/2017 for assessment year 2009-10 to 2011- 12 by order dated 14/09/2019. 6.2.11. Hon'ble Gujarat High Court, in case of Tata Teleservices vs.UOI reported in (2016) 385 ITR 497, on identical issue extensively dealt on the issue of retrospective applicability of the provisions by apply…

M/S. LIFE INSURANCE CORPORATION OF INDIA,CHITRADURGA vs. THE INCOME TAX OFFICER, (TDS)- WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 557/BANG/2020[2012-13]Status: DisposedITAT Bangalore21 Jan 2021AY 2012-13

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…ration unless such a construction appears very clearly in the terms of the Act, or arises by necessary and distinct implication. 6.2.10. This view is supported by following decisions: • Hon’ble ITAT Mumbai in case of Sodexo SVC India Pvt.Ltd reported in (2018 92 Taxmann.com 260 • ACIT vs.Acer India Pvt.Ltd in ITA No. 2570 to 2572/Bang/2017 for assessment year 2009-10 to 2011- 12 by order dated 14/09/2019. 6.2.11. Hon'ble Gujarat High Court, in case of Tata Teleservices vs.UOI reported in (2016) 385 ITR 497, on identical issue extensively dealt on the issue of retrospective applicability of the provisions by apply…

M/S LIFE INSURANCE CORPORATION OF INDIA,CHITRADURGA vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 556/BANG/2020[2011-12]Status: DisposedITAT Bangalore21 Jan 2021AY 2011-12

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…ration unless such a construction appears very clearly in the terms of the Act, or arises by necessary and distinct implication. 6.2.10. This view is supported by following decisions: • Hon’ble ITAT Mumbai in case of Sodexo SVC India Pvt.Ltd reported in (2018 92 Taxmann.com 260 • ACIT vs.Acer India Pvt.Ltd in ITA No. 2570 to 2572/Bang/2017 for assessment year 2009-10 to 2011- 12 by order dated 14/09/2019. 6.2.11. Hon'ble Gujarat High Court, in case of Tata Teleservices vs.UOI reported in (2016) 385 ITR 497, on identical issue extensively dealt on the issue of retrospective applicability of the provisions by apply…

M/S. LIFE INSURANCE CORPORATION OF INDIA,CHITRADURGA vs. THE INCOME TAX OFFICER, (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 555/BANG/2020[2011-12]Status: DisposedITAT Bangalore21 Jan 2021AY 2011-12

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…ration unless such a construction appears very clearly in the terms of the Act, or arises by necessary and distinct implication. 6.2.10. This view is supported by following decisions: • Hon’ble ITAT Mumbai in case of Sodexo SVC India Pvt.Ltd reported in (2018 92 Taxmann.com 260 • ACIT vs.Acer India Pvt.Ltd in ITA No. 2570 to 2572/Bang/2017 for assessment year 2009-10 to 2011- 12 by order dated 14/09/2019. 6.2.11. Hon'ble Gujarat High Court, in case of Tata Teleservices vs.UOI reported in (2016) 385 ITR 497, on identical issue extensively dealt on the issue of retrospective applicability of the provisions by apply…

M/S. LIFE INSURANCE CORPORATION OF INDIA,HAVERI vs. THE INCOME TAX OFFICER (TDS) - WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 554/BANG/2020[2016-17]Status: DisposedITAT Bangalore21 Jan 2021AY 2016-17

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…ration unless such a construction appears very clearly in the terms of the Act, or arises by necessary and distinct implication. 6.2.10. This view is supported by following decisions: • Hon’ble ITAT Mumbai in case of Sodexo SVC India Pvt.Ltd reported in (2018 92 Taxmann.com 260 • ACIT vs.Acer India Pvt.Ltd in ITA No. 2570 to 2572/Bang/2017 for assessment year 2009-10 to 2011- 12 by order dated 14/09/2019. 6.2.11. Hon'ble Gujarat High Court, in case of Tata Teleservices vs.UOI reported in (2016) 385 ITR 497, on identical issue extensively dealt on the issue of retrospective applicability of the provisions by apply…

M/S. LIFE INSURANCE CORPORATION OF INDIA,HAVERI vs. THE INCOME TAX OFFICER (TDS) - WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 553/BANG/2020[2016-17]Status: DisposedITAT Bangalore21 Jan 2021AY 2016-17

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…ration unless such a construction appears very clearly in the terms of the Act, or arises by necessary and distinct implication. 6.2.10. This view is supported by following decisions: • Hon’ble ITAT Mumbai in case of Sodexo SVC India Pvt.Ltd reported in (2018 92 Taxmann.com 260 • ACIT vs.Acer India Pvt.Ltd in ITA No. 2570 to 2572/Bang/2017 for assessment year 2009-10 to 2011- 12 by order dated 14/09/2019. 6.2.11. Hon'ble Gujarat High Court, in case of Tata Teleservices vs.UOI reported in (2016) 385 ITR 497, on identical issue extensively dealt on the issue of retrospective applicability of the provisions by apply…

M/S. LIFE INSURANCE CORPORATION OF INDIA,HAVERI vs. THE INCOME TAX OFFICER (TDS) - WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 552/BANG/2020[2015-16]Status: DisposedITAT Bangalore21 Jan 2021AY 2015-16

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…ration unless such a construction appears very clearly in the terms of the Act, or arises by necessary and distinct implication. 6.2.10. This view is supported by following decisions: • Hon’ble ITAT Mumbai in case of Sodexo SVC India Pvt.Ltd reported in (2018 92 Taxmann.com 260 • ACIT vs.Acer India Pvt.Ltd in ITA No. 2570 to 2572/Bang/2017 for assessment year 2009-10 to 2011- 12 by order dated 14/09/2019. 6.2.11. Hon'ble Gujarat High Court, in case of Tata Teleservices vs.UOI reported in (2016) 385 ITR 497, on identical issue extensively dealt on the issue of retrospective applicability of the provisions by apply…

M/S. LIFE INSURANCE CORPORATION OF INDIA,HAVERI vs. THE INCOME TAX OFFICER (TDS) - WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 551/BANG/2020[2015-16]Status: DisposedITAT Bangalore21 Jan 2021AY 2015-16

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…ration unless such a construction appears very clearly in the terms of the Act, or arises by necessary and distinct implication. 6.2.10. This view is supported by following decisions: • Hon’ble ITAT Mumbai in case of Sodexo SVC India Pvt.Ltd reported in (2018 92 Taxmann.com 260 • ACIT vs.Acer India Pvt.Ltd in ITA No. 2570 to 2572/Bang/2017 for assessment year 2009-10 to 2011- 12 by order dated 14/09/2019. 6.2.11. Hon'ble Gujarat High Court, in case of Tata Teleservices vs.UOI reported in (2016) 385 ITR 497, on identical issue extensively dealt on the issue of retrospective applicability of the provisions by apply…

M/S. LIFE INSURANCE CORPORATION OF INDIA,HAVERI vs. THE INCOME TAX OFFICER (TDS) - WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 550/BANG/2020[2014-15]Status: DisposedITAT Bangalore21 Jan 2021AY 2014-15

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…ration unless such a construction appears very clearly in the terms of the Act, or arises by necessary and distinct implication. 6.2.10. This view is supported by following decisions: • Hon’ble ITAT Mumbai in case of Sodexo SVC India Pvt.Ltd reported in (2018 92 Taxmann.com 260 • ACIT vs.Acer India Pvt.Ltd in ITA No. 2570 to 2572/Bang/2017 for assessment year 2009-10 to 2011- 12 by order dated 14/09/2019. 6.2.11. Hon'ble Gujarat High Court, in case of Tata Teleservices vs.UOI reported in (2016) 385 ITR 497, on identical issue extensively dealt on the issue of retrospective applicability of the provisions by apply…

M/S. LIFE INSURANCE CORPORATION OF INDIA,HAVERI vs. THE INCOME TAX OFFICER (TDS) - WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 549/BANG/2020[2014-15]Status: DisposedITAT Bangalore21 Jan 2021AY 2014-15

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…ration unless such a construction appears very clearly in the terms of the Act, or arises by necessary and distinct implication. 6.2.10. This view is supported by following decisions: • Hon’ble ITAT Mumbai in case of Sodexo SVC India Pvt.Ltd reported in (2018 92 Taxmann.com 260 • ACIT vs.Acer India Pvt.Ltd in ITA No. 2570 to 2572/Bang/2017 for assessment year 2009-10 to 2011- 12 by order dated 14/09/2019. 6.2.11. Hon'ble Gujarat High Court, in case of Tata Teleservices vs.UOI reported in (2016) 385 ITR 497, on identical issue extensively dealt on the issue of retrospective applicability of the provisions by apply…

M/S. LIFE INSURANCE CORPORATION OF INDIA,HAVERI vs. THE INCOME TAX OFFICER (TDS) - WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 548/BANG/2020[2013-14]Status: DisposedITAT Bangalore21 Jan 2021AY 2013-14

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…ration unless such a construction appears very clearly in the terms of the Act, or arises by necessary and distinct implication. 6.2.10. This view is supported by following decisions: • Hon’ble ITAT Mumbai in case of Sodexo SVC India Pvt.Ltd reported in (2018 92 Taxmann.com 260 • ACIT vs.Acer India Pvt.Ltd in ITA No. 2570 to 2572/Bang/2017 for assessment year 2009-10 to 2011- 12 by order dated 14/09/2019. 6.2.11. Hon'ble Gujarat High Court, in case of Tata Teleservices vs.UOI reported in (2016) 385 ITR 497, on identical issue extensively dealt on the issue of retrospective applicability of the provisions by apply…

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Sodex SVC India (P) Ltd. v. DCIT (TDS) 2(2) (92 Taxmann.com 260) — Cited in 86 Judgments | BharatTax