DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRLCE - 1(1), BENGALURU vs. APPLIED MATERIALS INDIA PRIVATE LIMITED, BENGALURU

In the result, all these 4 appeals filed by the Revenue are dismissed

115A of the Income tax Act 1961. Therefore there\nis no argument that, in order to bring the sum to tax, there need to be\nelement of profit.\n\n19. Further, the Hon'ble Delhi High court in M/S. CENTRICA INDIA\nOFFSHORE PVT LTD W.P. (C) No.6807/2012 had interalia observed as\nunder:\n\n\"The mere fact that CIOP

DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRCLE-1(1), BENGALURU vs. APPLIED MATERIALS INDIA PRIVATE LIMITED, BENGALURU

In the result, all these 4 appeals filed by the Revenue are dismissed

115A of the Income tax Act 1961. Therefore there\nto argue that, in order to bring the sum to tax, there need to be\naveeleraent of profit.\n19. Further, the Hon'ble Delhi High court in M/S. CENTRICA INDIA\nOFFSHORE PVT LTD W.P. (C) No.6807/2012 had interalia observed as\nunder:\n\"The mere fact that CIOP, and the secondment agreement

DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRCLE - 1(1), BENGALURU vs. APPLIED MATERIALS INDIA PRIVATE LIMITED, BENGALURU

In the result, all these 4 appeals filed by the Revenue are dismissed

115A of the Income tax Act 1961. Therefore there\nto argue that, in order to bring the sum to tax, there need to be\naveleraent of profit.\n\n19. Further, the Hon'ble Delhi High court in M/S. CENTRICA INDIA\nOFFSHORE PVT LTD W.P. (C) No.6807/2012 had interalia observed as\nunder:\n\n\"The mere fact that CIOP

M.S VODAFONE MOBILES 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

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

115A of the Act even on payments covered by the DTAAs. The Appellant craves leave to add, alter, amend or withdraw any of the above grounds at or before the hearing of the appeal.” IT(IT)A No. 2818/Bang/2017:- (By Assessee -Assessment Year: 2015-16) “The Appellant respectfully submits that: On the facts and circumstances of the case

VODAFONE SOUTH LIMITED,BANGALORE vs. DYDIT, 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

115A of the Act even on payments covered by the DTAAs. The Appellant craves leave to add, alter, amend or withdraw any of the above grounds at or before the hearing of the appeal.” IT(IT)A No. 2818/Bang/2017:- (By Assessee -Assessment Year: 2015-16) “The Appellant respectfully submits that: On the facts and circumstances of the case

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-2(2) INTERNATIONAL TAXATION , BANGALORE vs. M/S VODAFONE SOUTH LTD , 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

115A of the Act even on payments covered by the DTAAs. The Appellant craves leave to add, alter, amend or withdraw any of the above grounds at or before the hearing of the appeal.” IT(IT)A No. 2818/Bang/2017:- (By Assessee -Assessment Year: 2015-16) “The Appellant respectfully submits that: On the facts and circumstances of the case

DEPUTY COMMISSIONER OF INCOME-TAX,BANGALORE vs. M/S. VODAFONE SOUTH LTD.,, NEW DELHI

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

115A of the Act even on payments covered by the DTAAs. The Appellant craves leave to add, alter, amend or withdraw any of the above grounds at or before the hearing of the appeal.” IT(IT)A No. 2818/Bang/2017:- (By Assessee -Assessment Year: 2015-16) “The Appellant respectfully submits that: On the facts and circumstances of the case

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

115A of the Act even on payments covered by the DTAAs. The Appellant craves leave to add, alter, amend or withdraw any of the above grounds at or before the hearing of the appeal.” IT(IT)A No. 2818/Bang/2017:- (By Assessee -Assessment Year: 2015-16) “The Appellant respectfully submits that: On the facts and circumstances of the case

JOINT COMMISSIONER OF INCOME TAX (OSD) CIRCLE-2(1)(IT), BANGALORE vs. M/S VODAFONE SOUTH LTD , 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

115A of the Act even on payments covered by the DTAAs. The Appellant craves leave to add, alter, amend or withdraw any of the above grounds at or before the hearing of the appeal.” IT(IT)A No. 2818/Bang/2017:- (By Assessee -Assessment Year: 2015-16) “The Appellant respectfully submits that: On the facts and circumstances of the case

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

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

115A of the Act even on payments covered by the DTAAs. The Appellant craves leave to add, alter, amend or withdraw any of the above grounds at or before the hearing of the appeal.” IT(IT)A No. 2818/Bang/2017:- (By Assessee -Assessment Year: 2015-16) “The Appellant respectfully submits that: On the facts and circumstances of the case

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-2(2) INTERNATIONAL TAXATION , BANGALORE vs. M/S VODAFONE SOUTH LTD , 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

115A of the Act even on payments covered by the DTAAs. The Appellant craves leave to add, alter, amend or withdraw any of the above grounds at or before the hearing of the appeal.” IT(IT)A No. 2818/Bang/2017:- (By Assessee -Assessment Year: 2015-16) “The Appellant respectfully submits that: On the facts and circumstances of the case

DCIT, BANGALORE vs. M/S VODAFONE SOUTH LTD.,, NEW DELHI

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

115A of the Act even on payments covered by the DTAAs. The Appellant craves leave to add, alter, amend or withdraw any of the above grounds at or before the hearing of the appeal.” IT(IT)A No. 2818/Bang/2017:- (By Assessee -Assessment Year: 2015-16) “The Appellant respectfully submits that: On the facts and circumstances of the case

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

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

115A of the Act even on payments covered by the DTAAs. The Appellant craves leave to add, alter, amend or withdraw any of the above grounds at or before the hearing of the appeal.” IT(IT)A No. 2818/Bang/2017:- (By Assessee -Assessment Year: 2015-16) “The Appellant respectfully submits that: On the facts and circumstances of the case

VODAFONE SOUTH LIMITED,BANGALORE vs. DYDIT, 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

115A of the Act even on payments covered by the DTAAs. The Appellant craves leave to add, alter, amend or withdraw any of the above grounds at or before the hearing of the appeal.” IT(IT)A No. 2818/Bang/2017:- (By Assessee -Assessment Year: 2015-16) “The Appellant respectfully submits that: On the facts and circumstances of the case

M/S VODAFONE MOBILE SERVICES LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER 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

115A of the Act even on payments covered by the DTAAs. The Appellant craves leave to add, alter, amend or withdraw any of the above grounds at or before the hearing of the appeal.” IT(IT)A No. 2818/Bang/2017:- (By Assessee -Assessment Year: 2015-16) “The Appellant respectfully submits that: On the facts and circumstances of the case

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

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

115A of the Act even on payments covered by the DTAAs. The Appellant craves leave to add, alter, amend or withdraw any of the above grounds at or before the hearing of the appeal.” IT(IT)A No. 2818/Bang/2017:- (By Assessee -Assessment Year: 2015-16) “The Appellant respectfully submits that: On the facts and circumstances of the case

DEPUTY COMMISSIONER OF INCOME TAX,BANGALORE vs. M/S.VODAFONE SOUTH LTD.,, NEW DELHI

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

115A of the Act even on payments covered by the DTAAs. The Appellant craves leave to add, alter, amend or withdraw any of the above grounds at or before the hearing of the appeal.” IT(IT)A No. 2818/Bang/2017:- (By Assessee -Assessment Year: 2015-16) “The Appellant respectfully submits that: On the facts and circumstances of the case

ELECTRICAL MATERIALS CENTER CO. LTD.,,BANGALORE vs. DY.D.I.T., BANGALORE

In the result, the appeal of the assessee is partly allowed for statistical

Bench: Shri A. K. Garodia & Shri Vijay Pal Rao

115A of the Act irrespective of there being no Article in the DTAA for taxation of fees for technical services and the appellant not having Permanent Establishment (PE') in India. 3. Holding the appellant to have constituted a Service PE in India On the facts and in the circumstances of the case, the learned AO erred

M/S AD2PRO MEDIA SOLUTIONS PRIVATE LIMITED ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-1(1), BANGALORE

In the result, all the 14 appeals filed by the assessee are allowed

Bench: Shri A.K.Garodia & Shri P.K.Gadale(Ita Nos.490 To 503(Bang)/2019) (Assessment Years: 2011-12 To 2017-18) M/S Ad2Pro Media Solutions Pvt.Ltd., No.10, 2Nd Floor, Bannerghatta Road, J.P.Nagar-Iii Phase, Bangalore-560078 Appellant Vs The Deputy Commissioner Of Income Tax, (International Taxation) Circle-1(1), Bmtc Building, Koramangala, Bangalore-560095 Respondent

disallowance. 10.2. This claim deserves to be rejected for the following reasons: 1) Ld AR filed a 'Note' on Pg 414, claiming to have filed it before that AO. No evidence was furnished as to whether this was actually filed before that AO and whether that AO had made enquiry on this issue. 2) The orders of Corporate