VODAFONE CELLULAR LIMITED,COIMBATORE vs. DCIT, COIMBATORE

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

194J r.w.s Explanation 2 to (vii) of section 9 is a special provision in the Act defining technical services, it will override the general reference to supply of labour for carrying out any work contained in Section 194C of the Act. Further, on facts also it was seen in the assessee's case that personnel for performing front office, managerial