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

92 Taxmann.com 260Income Tax Appellate Tribunal2018#1325 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 366,470 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)

M/S. Life Insurance Corporation of India, Davangere 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 527/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, Davangere 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 526/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, Davangere 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 525/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, Davangere 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 524/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, Davangere 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 523/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, Davangere 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 522/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, Davangere 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 521/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, Davangere 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 520/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, Davangere 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 519/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, Thirthahalli 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 518/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, Thirthahalli 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 517/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, Thirthahalli 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 516/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 Insrance Corporation of India, Thirthahalli 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 515/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, Thirthahalli 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 514/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, Thirthahalli 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 513/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, Thirthahalli 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 512/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, Thirthahalli 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 511/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, Thirthahalli 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 510/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, Thirthahalli 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 509/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, Thirthahalli 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 508/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…