M/S VODAFONE SOUTH LIMITED ,BANGALORE vs. DEPUTY DIRECTOR OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-1(1), BANGALORE

In the result, all three Stay petitions are dismissed, five appeals of the assessee for A

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

6. For that, the Ld. CIT (Appeals) erred in law as well as on facts in holding that, there is no scope for deduction of tax at the rate of 20%, as provided under the provisions of Section 206AA, when the benefit of DTAA is available; despite the overriding effect of Section 206AA of the Income

M/S VODAFONE MOBILE SERVICES LIMITED ,BANGALORE vs. DEPUTY DIRECTOR OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-1(1), BANGALORE

In the result, all three Stay petitions are dismissed, five appeals of the assessee for A