M/S VALUE FIRST DIGITAL MEDIA PVT. LTD.,,NEW DELHI vs. DCIT, NEW DELHI
ITA 4389/DEL/2015[2010-11]Status: DisposedITAT Delhi21 Nov 2019AY 2010-11
Bench: Shri N.K. Billaiya & Ms. Suchitra Kamble
Section 143(3)Section 37Section 40Section 72ASection 9Section 9(1)(vi)
…d to Rackspace has already been allowed by Hon’ble Mumbai Tribunal in the case of ITO vs People Interactive (I) P Ltd [ITA No 2179 to 2182 of 2009] relying upon the decision of Delhi High Court judgment in the case of Asia Satellite Telecommunications Co ltd [323 ITR 340], 2.4 That on the facts and circumstances of the case and in law, Ld. AO erred on ignoring the fact that Rackspace is one of the party to whom the appellant has paid server hosting charges. 2.5 That on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in not appreciating the fact that payments were made to non-reside…