How many judgments cite Vodafone India Services (P.) Ltd. v. Union of India?

172 judgments on BharatTax cite Vodafone India Services (P.) Ltd. v. Union of India (368 ITR 1), spanning 2015 to 2026.

Which sections of the Income Tax Act does Vodafone India Services (P.) Ltd. v. Union of India come up under?

It is most often cited in judgments turning on Section 143(3), Section 68, Section 147, Section 131, Section 144C(13), Section 148.

Vodafone India Services (P.) Ltd. v. Union of India

368 ITR 1High Court2014#563 most cited

What is Vodafone India Services (P.) Ltd. v. Union of India authority for?

The issue of shares and share premium is a capital account transaction, not an income-generating event, therefore Chapter X (Transfer Pricing) provisions are not attracted to deem notional or hypothetical income from such transactions.

172

judgments rely on this decision, according to BharatTax’s citation analysis of 367,368 Indian tax judgments — from 2015 to 2026.

Also referred to as

Vodafone India Services v. UOI · issue of shares · share premium · capital account transaction · transfer pricing · Chapter X applicability · international transaction · notional income · section 92 · section 56(2)(viib)

Also reported as

50 Taxmann.com 300228 Taxmann 25

Sections most often in play

Section 143(3)Section 68 Section 147 Section 131 Section 144C(13)Section 148 Section 263 Section 144C

Read the full judgment

Issues it is cited on

section 56(1)section 92(1)section 56(2)(viib)dcf method onus of proof share capital and share premium source of source section 40a(2)(b)disallowance of interest expenditure share application money section 40a(2)section 92b

Judgments citing Vodafone India Services (P.) Ltd. v. Union of India

Piramal Healthcare Ltd, Mumbai vs. DCIT 7(1), Mumbai

The appeal of the revenue is partly allowed for statistical purposes in terms of our aforesaid observations

ITA 1257/MUM/2014[2009-10]Status: DisposedITAT Mumbai07 May 2019AY 2009-10

Bench: Shri G.S.Pannu & Shri Ravish Soodpiramal Healthcare Limited Deputy Commissioner Of Income (Now Known As Piramal Enterprises Ltd.) Tax- 7(1) Piramal Tower, Room No. 622, Aayakar Bhavan, Ganpatrao Kadam Marg, Vs. M.K. Road Lower Parel, Mumbai- 400 020 Mumbai – 400 013

For Appellant: Sh. J.D, Mistry, Senior Advocate &For Respondent: S/sh. Bhupendra Kumar Singh &

Section 143(3)Section 35

…corporate guarantee provided by the assessee on behalf of its „AE‟. In support of his aforesaid contention the ld. A.R tried to draw support from the judgment of the Hon‟ble High Court of Bombay in the case of Vodafone India Services Pvt. Ltd. Vs. CIT (2014) 368 ITR 1 (Bom). It was submitted by him that since the guarantee was given by the assessee to its „AE‟ for its own benefit, therefore, the question of charging any guarantee commission did not arise at all. Alternatively, it was submitted by the ld. A.R that in the assesses own case for A.Y 2008-09 the Tribunal had in all fairness directed the A.O to determ…

Capri Global Advisory Services P. Ltd, Mumbai vs. DCIT 1(1)(1), Mumbai

ITA 170/MUM/2017[2009-10]Status: DisposedITAT Mumbai10 Apr 2019AY 2009-10

Bench: Hon’Ble Shri Mahavir Singh, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Jitendra Jain/Mahesh Rajora-Ld.ARsFor Respondent: Abhi Rama Kartikeyan - Ld.DR

Section 143(3)Section 147Section 147rSection 148Section 68

…CIT Vs. Lovely Exports P. Ltd. [216 CTR 195] to arrive at the said conclusion. Reliance was also placed on CBDT instruction No. 2/2015 dated 29/01/2015 and judgment of Hon’ble Bombay High Court rendered in Vodafone India Services Pvt. Ltd. Vs. Union of India [368 ITR 1] to conclude that the receipt of share capital was capital in nature and therefore, the same could not be brought to tax in the hands of the assessee. 3.3 The aforesaid conclusions drawn by first appellate authority has given rise to cross-appeals before us. The assessee, in its appeal, is contesting the validity of reassessment proceedings wherea…

ITO WD 6(1)(2), Mumbai vs. Ample Holdings P.Ltd, Mumbai

In the result, the appeal of Revenue is dismissed

ITA 1628/MUM/2017[2010-11]Status: DisposedITAT Mumbai04 Apr 2019AY 2010-11

Bench: Sri Mahavir Singh, Jm & Sri G Manjunatha, Am

For Appellant: Shri Anadi Verma, DRFor Respondent: S/Shri Vijay Mehta &

Section 139(1)Section 142(1)Section 143(1)Section 143(3)Section 147Section 148Section 56(2)(viib)

…ication for charging the share premium over and above intrinsic value of the share premium. Prima- facie, we are of the view that the basis of the impugned Notice stands concluded by the decision of this Court in Vodafone India Services (P.)Ltd. v. CIT [2014] 368 ITR 1/50 taxmann.com 300/[2015] 228 Taxman 25 (Bom.), wherein it has been held that the share premium being on the capital amount cannot be subjected to tax as income.” 11. In view of the above facts and circumstances and precedence decided by Hon’ble Bombay High Court and Hon’ble Delhi High court, we affirm the order of CIT(A) quashing the reassessment…

Assistant Commissioner of Income Tax, Circle-2, Jaipur vs. M/S Ganpati Exclusive Designer Sarees Pvt. Ltd., Jaipur

In the result, appeal of the assessee is allowed

ITA 696/JPR/2018[2009-10]Status: DisposedITAT Jaipur29 Mar 2019AY 2009-10

For Appellant: Shri Vijay Goyal (CA) &For Respondent: Shri Ashok Khanna (JCIT) fu/kZkfjrh dh vksj ls@

Section 14Section 143(3)Section 147Section 148Section 56Section 56(1)

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES “A”, JAIPUR Jh jes'k lh 'kekZ] ys[kk lnL; ,oa Jh fot; iky jko] U;kf;d lnL; ds le{k BEFORE: SHRI RAMESH C SHARMA, AM & SHRI VIJAY PAL RAO, JM vk;dj vihy la-@ITA No. 696/JP/2018 fu/kZkj.k o"kZ@Assessment Year :2009-10 cuke A.C.I.T., M/s Ganpati Exclusive Designer Vs. Circle-2, Sarees Pvt. Ltd., Jaipur. 154, Haldiyon Ka Rasta, Johari Bazar, Jaipur. LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AADCG 0084 E vihykFkhZ@Appellant izR;FkhZ@Respondent vk;dj vihy la-@ITA No. 1081/JP/2018 fu/kZkj.k o"kZ@Assessment Year :2014-15 cuke…

M/S Ganpati Exclusive Designer Sarees Pvt. Ltd., Jaipur vs. Assistant Commissioner of Income Tax, Circle-2, Jaipur

In the result, appeal of the assessee is allowed

ITA 1081/JPR/2018[2014-15]Status: DisposedITAT Jaipur29 Mar 2019AY 2014-15

For Appellant: Shri Vijay Goyal (CA) &For Respondent: Shri Ashok Khanna (JCIT) fu/kZkfjrh dh vksj ls@

Section 14Section 143(3)Section 147Section 148Section 56Section 56(1)

Nandlal Tolani Charitable Trust, Mumbai vs. ITO (E)2(1), Mumbai

In the result, appeal filed by the assessee is dimissed

ITA 106/MUM/2016[2012-13]Status: DisposedITAT Mumbai29 Mar 2019AY 2012-13

Bench: Shri Sandeep Gosain () & Shri G Manjunatha () Nandlal Tolani Charitable Vs Ito (E)-2(1), Mumbai Trust, 10-A, Bhkhtawar, Nariman Point, Mumbai 400 021 Pan : Aaatn0043Q Appellant Respondednt

Section 11Section 11(2)Section 12ASection 24

…mption u/sl 1 of the Act on the portion of income utilized for objects of the Trust. 2. The Learned A.O. as well as Learned CIT(A) have erred in not following the principles settled by Hon'ble Bombay High Court in the case of Vodafone India Services Pvt. Ltd. 368 ITR 531 (Bom) (Page 544) which is binding on Department in Mumbai as law of the land wherein it is held that income chargeable to tax has to be computed u/s.l4 of the Act and therefore income from property has to be computed allowing deduction u/s.24(a) of the Act in the case of all assesses including charitable trusts. 3. The Learned A.O. as well as Lea…

DCIT 4(3)(1), Mumbai vs. Patodia Filaments P. Ltd, Mumbai

ITA 5684/MUM/2017[2010-11]Status: DisposedITAT Mumbai26 Mar 2019AY 2010-11

Bench: Shri Rajesh Kumar & Shri Amarjeet Singhassessment Year: 2010-11

For Appellant: Shri Mani Jain, A.RFor Respondent: Shri Abi Rama Kartikeyan, D.R

Section 115JSection 148Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “C”, MUMBAI BEFORE SHRI RAJESH KUMAR, ACCOUNTANT MEMBER AND SHRI AMARJEET SINGH, JUDICIAL MEMBER Assessment Year: 2010-11 DCIT 4(3)(1), M/s. Patodia Filaments P. Room No.649, 6th Floor, Ltd., Aayakar Bhavan, A-604, 6th Floor, M.K. Road, Express Zone, Mumbai - 400020 Vs. Opp. Oberoi Mall, Western Express Highway, Goregaon (E), Mumbai – 400 063 PAN: AABCP8673J (Appellant) (Respondent) Present for: Assessee by : Shri Mani Jain, A.R. Revenue by : Shri Abi Rama Kartikeyan, D.R. Date of Hearing : 25.02.2019 Date of Pronouncement : 26.03.2019 O R D E R Per Rajesh K…

M/S. Earnest Towers Private Limited, Kolkata vs. ACIT, Circle - 2(1), Kolkata

In the result, the appeal of the assessee is allowed in part

ITA 2530/KOL/2017[2013-14]Status: DisposedITAT Kolkata15 Mar 2019AY 2013-14

Bench: Sri J. Sudhakar Reddy & Sri S.S. Viswanethra Ravii.T.A. No. 2530/Kol/2017 Assessment Year: 2013-14 M/S. Earnest Towers Private Limited……….………....………………...…………………….….Appellant [Pan : Aabce 8612 N] Vs. Acit, Circle-2(1), Kolkata………............................................................…....….…………..…...Respondent Appearances By: Shri Ajit Kumar Jain & Siddhesh Chaugule, C.A Appearing On Behalf Of The Appellant. Shri P. K. Srihari, Cit- Dr, Appearing On Behalf Of The Respondent.

Section 144CSection 2(24)

…idered. We find force in the argument of the learned A.R. for the assessee for the assessee on this issue. 7.1.2 In any case the concept of potential income has been dealt with by the Hon'ble Bombay High Court in the case of Vodafone India Services Pvt. Ltd. (368 ITR 1)(Vodafone IV) at para 31, 32 and 43 of its order as under:- "31. Similarly, the reliance by the revenue upon the definition of International Taxation in the sub-clause (c) and (e) of Explanation (i) to Section 92B of the Act to conclude that Income has to be given a broader meaning to include notional income, as otherwise Chapter X of the Act would…

DCIT, New Delhi vs. M/S. Unitech Ltd., New Delhi

In the result this issue is allowed in favour of the assessee

ITA 311/DEL/2016[2011-12]Status: DisposedITAT Delhi12 Feb 2019AY 2011-12

Bench: Shri Amit Shukla & Shri L.P. Sahu

For Appellant: Shri Shailesh Gupta, AdvocateFor Respondent: Shri H.K. Choudhary CIT-D.R

Section 144CSection 36(1)(iii)

…on of a share application money as deemed loan transaction is not permissible under the Act and in support he relied upon the following judgements: - (i) Judgment of Hon’ble Bombay High Court in the case of Vodafone India Services (P.) Ltd. vs UOI reported in 368 ITR 1 (ii) Order of Hon’ble ITAT Delhi in the case of First Blue Home Finance Ltd. vs. DCIT in ITA No. 3072/Del/2013 (iii) Order of Hon’ble ITAT Mumbai Aegis Limited vs. ACIT in ITA No. 1213/M/2014. (iv) Bharti Airtel vs ACIT (ITAT Delhi) reported in 161 TTJ 428. 23.1 He further submitted that the reasonable period in case of share application money remi…

M/S. Unitech Limited, New Delhi vs. DCIT, New Delhi

In the result this issue is allowed in favour of the assessee

ITA 6585/DEL/2015[2011-12]Status: DisposedITAT Delhi12 Feb 2019AY 2011-12

Bench: Shri Amit Shukla & Shri L.P. Sahu

For Appellant: Shri Shailesh Gupta, AdvocateFor Respondent: Shri H.K. Choudhary CIT-D.R

Section 144CSection 36(1)(iii)

Harish Mittal, Faridabad vs. ITO, Ward-1(3), Faridabad

In the result, the Appeal filed by the Assessee stands allowed

ITA 5313/DEL/2018[2008-09]Status: DisposedITAT Delhi05 Feb 2019AY 2008-09

Bench: Shri H.S. Sidhuassessment Year: 2008-09

For Appellant: SH. R.K. MALHOTRA, ADVOCATEFor Respondent: SH. S.L. ANURAGI, SR. DR

Section 127(1)Section 147Section 234A

…a bona fide one. Therefore, where Assessing Officer had not made any addition in respect of escaped income for which he had recorded reasons, assessment order was liable to be cancelled. Oriental Bank of Commerce v. Addl. CIT (2014) 49 Taxmann 485 I (2015) 228 Taxmann 25 / (2014) 272 CTR 56 (DELHI) In this case no additions were made in respect of grounds assigned for reopening / assessment, it was not open to Assessing Officer to independently assess some other income. Held that from the review of case laws it was evident that if no additions were made in respect of the said reasons, it was not open to th…

DCIT 4(1)(2), Mumbai vs. Ab & Co Global P. Ltd, Mumbai

ITA 3280/MUM/2017[2012-13]Status: DisposedITAT Mumbai30 Jan 2019AY 2012-13

Bench: Shri Joginder Singh () & Shri N.K. Pradhan () Assessment Year: 2012-13 Dcit-4(1)(2), Room No. 640, M/S Ab & Co. Global 6Th Floor, Aayakar Bhavan, Vs. Pvt. Ltd. 30, 2Nd Floor, M.K. Road, Mumbai-400020. Gopal Bhuvan, 199, Princess Street, Kalbadevi Road, Mumbai-400002. Pan No. Aaeca1095J Appellant Respondent Revenue By : Mr. Satish Chandra Rajore, Dr Assessee By : Mr. Jitendra Singh, Ar Date Of Hearing : 09/01/2019 Date Of Pronouncement : 30/01/2019

For Appellant: Mr. Jitendra Singh, ARFor Respondent: Mr. Satish Chandra Rajore, DR

Section 143(3)Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “A” MUMBAI BEFORE SHRI JOGINDER SINGH (VICE PRESIDENT) AND SHRI N.K. PRADHAN (ACCOUNTANT MEMBER) Assessment Year: 2012-13 DCIT-4(1)(2), Room No. 640, M/s AB & Co. Global 6th Floor, Aayakar Bhavan, Vs. Pvt. Ltd. 30, 2nd floor, M.K. Road, Mumbai-400020. Gopal Bhuvan, 199, Princess Street, Kalbadevi Road, Mumbai-400002. PAN No. AAECA1095J Appellant Respondent Revenue by : Mr. Satish Chandra Rajore, DR Assessee by : Mr. Jitendra Singh, AR Date of Hearing : 09/01/2019 Date of pronouncement : 30/01/2019 ORDER PER N.K. PRADHAN, AM This is an appeal filed by the Reven…

Balbir Ispat P.Ltd, Mumbai vs. ITO 6(1)(2), Mumbai

In the result, the appeal of assessee is allowed

ITA 6953/MUM/2016[2009-10]Status: DisposedITAT Mumbai28 Jan 2019AY 2009-10

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am

For Appellant: Shri Prakash Jhunjhunwala, ARFor Respondent: Shri Ashish V. Pophane, DR

Section 142(1)Section 143(1)Section 143(3)Section 147Section 148

…आयकर अपीलीय अधिकरण “B” न्यायपीठ म ुंबई में। IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI श्री महावीर स िंह, न्याययक दस्य एविं श्री राजेश कुमार लेखा दस्य के मक्ष । BEFORE SRI MAHAVIR SINGH, JM AND SRI RAJESH KUMAR, AM Aayakr ApIla saM./ ITA No. 6953/Mum/2016 (inaQa-arNa baYa- / Assessment Year 2009-10) Balbir Ispat Pvt. Ltd. The Income Tax Officer, 207, Steel Centre, Ward 6(1)(2), Room No. 6th Ahmedabad Street, Carnac 508, Floor, Aayakar Vs. Bunder, Masjid (E), Bhavan, Maharshi Karve Mumbai-400 051 Road Churchgate, Mumbai- 400 020 (ApIlaaqaI- / Appellant) .. (p`%yaqaaI- / Respondent) स्थायी लेखा िं./PA…

ITO 6(1)(3), Mumbai vs. Arogya Bharti Health Park P.Ltd, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 2943/MUM/2014[2010-11]Status: DisposedITAT Mumbai17 Oct 2018AY 2010-11

Bench: Shri Joginder Singh() & Shri G Manjunatha ()

Section 143(2)Section 68

…ospective in nature which is applicable from AY 2013-14, therefore, the said amendment cannot be applied to the assessment year in question. The Ld.AR further submitted that the Hon’ble Bombay High Court in the case of Vodafone India Services Pvt Ltd vs UOI 368 ITR 1 (Bom) made it very clear that amount received on account of share application money is a capital receipt and the nature and source of the investment is explained, then there is no scope for making addition u/s 68 of the Income-tax Act, 1961. The Ld.AR further submitted that the assessee has filed various details to prove valuation of shares and…

DCIT, Cir-11(1), Kolkata vs. M/S. at & S India Pvt. Ltd., Mysore

In the result, all three appeals filed by the Revenue are dismissed

ITA 975/KOL/2017[2010-11]Status: DisposedITAT Kolkata05 Oct 2018AY 2010-11

Bench: Sh. J.Sudhakar Reddy & Sh. A.T.Varkey

…IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA BENCH “C”, KOLKATA BEFORE SH. J.SUDHAKAR REDDY, ACCOUNTANT MEMBER AND SH. A.T.VARKEY, JUDICIAL MEMBER ITA No.515/KOL/2016, 974 & 975/KOL/2017 [Assessment Year: 2011-12, 2009-10, 2010-11] DCIT, v s M/s. AT & S Pvt.Ltd., Circle-11(1), Aayakar 12A, Industrial Area, Nanjangud, Bhawan, P-7, Mysore, Karnataka-741251. Chowringhee Square, PAN-AAECA2930J Kolkata-700069. (Appellant) (Respondent) Appellant by Sh.G.Mallikarjuna, CIT & Sh. Sanjay Paul, Addl. CIT Sr. DR Respondent by Ms. Rituparna Sinha & Sh. Anup Sinha, AR Date of Hearing 07.08.2018 Date of Pronouncement 05.10.201…

DCIT, Cir-11(1), Kolkata vs. M/S at & S Pvt. Ltd., Karnataka

In the result, all three appeals filed by the Revenue are dismissed

ITA 515/KOL/2016[2011-2012]Status: DisposedITAT Kolkata05 Oct 2018AY 2011-2012

Bench: Sh. J.Sudhakar Reddy & Sh. A.T.Varkey

Asst CIT (Ltu) 2, Mumbai vs. Reliance Industries Ltd, Mumbai

ITA 1547/MUM/2016[2010-11]Status: DisposedITAT Mumbai28 Sept 2018AY 2010-11

Bench: S/Shri B.R.Baskaran (Am) & Amarjit Singh (Jm)

Section 43B

…given by the assessee to its AE. Accordingly he made T.P adjustment of Rs.124.17 lakhs. The Tribunal, by placing reliance on the decision rendered 29 M/s. Reliance Industries limited by Hon’ble Bombay High Court in the case of Vodafone India Services P Ltd (368 ITR 1) held that there is no income/potential income arising to the assessee out of impugned international transaction of investment in acquiring shares in its subsidiary Tops BV, Netherlands and hence the same would fall outside the purview of Indian Transfer Pricing provisions. The Tribunal also held that the outbound transactions are also covered by t…

ACIT-16(1), Mumbai vs. Golden Line Studio Pvt. Ltd., Mumbai

In the result, the appeal filed by the revenue is dismissed

ITA 6146/MUM/2016[2011-12]Status: DisposedITAT Mumbai31 Aug 2018AY 2011-12

Bench: Shri B.R. Baskaran (Am) & Shri Ramlal Negi (Jm)

Section 68

…5)(62 taxmann.com 80). The assessee also contended that Share premium is a Capital receipt and for this purpose, it took support of the decision rendered by Hon’ble Bombay High Court in the case of Vodafone India Services P Ltd vs. Union of India & Ors (2014)(368 ITR 1). The above said contention was accepted by Le CIT(A), in view of the Instruction No.500/15/2014/APA-1 dated 29-01-2015 issued by CBDT, wherein the CBDT has stated that it has accepted the decision of Hon’ble Bombay High Court referred above and also directed the DRP and CIT(A) to follow the above said decision. Further, the CIT(A) also noticed tha…

DCIT Cir 6(3)(2), Mumbai vs. Kargwal Construction P. Ltd, Mumbai

In the result, the appeal filed by the revenue and the cross- objection by the assessee are dismissed

ITA 7108/MUM/2016[2009-10]Status: DisposedITAT Mumbai21 Aug 2018AY 2009-10

Bench: Shri C.N. Prasad () & Shri N.K. Pradhan () Assessment Year: 2009-10 Acit Cir-6(3)(2), Room No. M/S Kargwal 522, 5Th Floor, Aayakar Construction Pvt. Ltd. Vs. Bhavan, M.K. Road, 107, First Floor, Mumbai-400020. Runwal Omkar Esquare, Off Eastern Exp. Highway, Sion, Mumbai-400022 Pan No. Aadck1853D Appellant Respondent Co No. 75/Mum/2018 (Ita No. 7108/Mum/2016) Assessment Year: 2009-10 M/S Kargwal Construction Acit Cir-6(3)(2), Pvt. Ltd. 107, First Floor, Room No. 522, 5Th Vs. Runwal Omkar Esquare, Off Floor, Aayakar Bhavan, Eastern Exp. Highway, Sion, M.K. Road, Mumbai- Mumbai-400022 400020. Pan No. Aadck1853D Appellant Respondent

For Appellant: Mr. Dharmesh Shah, ARFor Respondent: Mr. M. Naveen, DR

Section 133(6)Section 143(1)Section 143(3)Section 147Section 148Section 68

…ix) CIT v. Batra Bhatta Company [220 CTR 531] (Del.), (x) Krupesh Ghanshyambhai Thakkar v. DCIT [77 taxmann.com 293] (Guj.), (xi) Khubchandani Healthparks Pvt. Ltd. v. ITO & Ors [384 ITR 322] (Bom.), (xii) Vodafone India Services Ltd. v. Union of India & Ors [368 ITR 1] (Bom.). Reliance is also placed on CBDT’s Instruction No. 2/2015 [F. No. 500/15/2014-APA-I] dated 29.01.2015. 6.1 The Ld. counsel submits that reopening of the assessment cannot be done without presence of tangible external source of information obtained subsequent to the passing of the earlier assessment order. It is stated that in the present ca…

Shilpa Shetty, Mumbai vs. ACIT CC 13, Mumbai

ITA 2445/MUM/2014[2010-11]Status: DisposedITAT Mumbai21 Aug 2018AY 2010-11

Bench: Hon’Ble Sh. R. C. Sharma, Am & Hon’Ble Sandeep Gosain, Jm आयकरअपीलसं./ I.T.A. No. 2445/Mum/2014 (निर्धारणवर्ा / Assessment Year: 2010-11)

For Appellant: Shri Arvind V. SondeFor Respondent: Shri V. Jenardhanan

Section 92ASection 92A(2)(j)Section 92CSection 92F

…t Pg. 472 vi. Goodyear Tire & Rubber Co. [2011] 334 ITR 69 (AAR) - Para 10 at Pg. 78 vii. Vodafone India Services (P.) Ltd. v. Union of India [2013] 361 ITR 531 (Born HC) - Para 32 at Pg. 564 viii. Vodafone India Services (P.) Ltd. v. Union of India [2014] 368 ITR 1 (Born HC) - Para 24 (Pg. 30), 40 (Pg. 37-38) ix. Vodafone India Services (P.) Ltd. v. Union of India [2015] 369 ITR 511 (Born HC) - Para 8 at Pg. 515 x. Vodafone India Services (P.) Ltd. v. CIT [2016] 385 ITR 169 (Born HC) - Pg. 312 and 320 The Ld. AR further submitted that when the machinery provisions fail, then the charging provisions cannot…