DHARAMVIR KHOSLA,. vs. DCIT CC-5, NEW DELHI , .

The appeals are allowed for statistical purposes and ld

1) of the Act and Rs. 17,03,974 was\nshortly allowed. There is no reason given in the intimation at page 16-17 of the\npaper-book at page 4 of the details of TDS on non salary was given and it is found\nfrom Form 26AS that TDS deducted from the amount paid/credited by various\nparties

BHARTI AIRTEL LTD.,GURGAON vs. ITO (TDS), NEW DELHI

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

TDS) vs. Bharti Airtel Ltd.] Madras High Court in the case of M/s Skycell Communication Ltd: 251 ITR 253, deleted the interest levied U/S 201(1A) on the ground that the interconnection/port access charges paid by the appellant to MTNL were not in the nature of "fee for technical services" under section 194J read with Explanation 2 to section

BHARTI AIRTEL LTD.,GURGAON vs. ITO (TDS), NEW DELHI

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

TDS) vs. Bharti Airtel Ltd.] Madras High Court in the case of M/s Skycell Communication Ltd: 251 ITR 253, deleted the interest levied U/S 201(1A) on the ground that the interconnection/port access charges paid by the appellant to MTNL were not in the nature of "fee for technical services" under section 194J read with Explanation 2 to section

BHARTI AIRTEL LTD.,GURGAON vs. ITO (TDS), NEW DELHI

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

TDS) vs. Bharti Airtel Ltd.] Madras High Court in the case of M/s Skycell Communication Ltd: 251 ITR 253, deleted the interest levied U/S 201(1A) on the ground that the interconnection/port access charges paid by the appellant to MTNL were not in the nature of "fee for technical services" under section 194J read with Explanation 2 to section

ITO (TDS), NEW DELHI vs. BHARTI AIRTEL LTD., GURGAON

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

TDS) vs. Bharti Airtel Ltd.] Madras High Court in the case of M/s Skycell Communication Ltd: 251 ITR 253, deleted the interest levied U/S 201(1A) on the ground that the interconnection/port access charges paid by the appellant to MTNL were not in the nature of "fee for technical services" under section 194J read with Explanation 2 to section

ITO (TDS), NEW DELHI vs. BHARTI AIRTEL LTD., GURGAON

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

TDS) vs. Bharti Airtel Ltd.] Madras High Court in the case of M/s Skycell Communication Ltd: 251 ITR 253, deleted the interest levied U/S 201(1A) on the ground that the interconnection/port access charges paid by the appellant to MTNL were not in the nature of "fee for technical services" under section 194J read with Explanation 2 to section

BHARTI AIRTEL LTD.,GURGAON vs. ITO (TDS), NEW DELHI

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

TDS) vs. Bharti Airtel Ltd.] Madras High Court in the case of M/s Skycell Communication Ltd: 251 ITR 253, deleted the interest levied U/S 201(1A) on the ground that the interconnection/port access charges paid by the appellant to MTNL were not in the nature of "fee for technical services" under section 194J read with Explanation 2 to section

SH. VODAFONE DIGILINK LTD.,KARNAL vs. CIT (TDS), CHANDIGARH

In the result, all the 03 Appeals i

Bench: Shri H.S. Sidhu & Shri Prashant Maharishi

251 ITR 53, wherein it has been held as under: "Technical service referred in section 9(1) (vii) contemplates rendering of a "service" to the payer of the fee. Mere collection of a "for use of a standard facility provided to all those willing to pay for it does not amount to the fee having been received for technical services

SH. VODAFONE DIGILINK LTD.,KARNAL vs. CIT (TDS), CHANDIGARH

In the result, all the 03 Appeals i

Bench: Shri H.S. Sidhu & Shri Prashant Maharishi

251 ITR 53, wherein it has been held as under: "Technical service referred in section 9(1) (vii) contemplates rendering of a "service" to the payer of the fee. Mere collection of a "for use of a standard facility provided to all those willing to pay for it does not amount to the fee having been received for technical services

SH. VODAFONE DIGILINK LTD.,KARNAL vs. CIT (TDS), CHANDIGARH

In the result, all the 03 Appeals i

Bench: Shri H.S. Sidhu & Shri Prashant Maharishi

251 ITR 53, wherein it has been held as under: "Technical service referred in section 9(1) (vii) contemplates rendering of a "service" to the payer of the fee. Mere collection of a "for use of a standard facility provided to all those willing to pay for it does not amount to the fee having been received for technical services

VODAFONE MOBILE SERVICES LTD.,,NEW DELHI vs. ITO, KARNAL

In the result, all the 03 Appeals i

Bench: Shri H.S. Sidhu & Shri Prashant Maharishi

251 ITR 53, wherein it has been held as under: "Technical service referred in section 9(1) (vii) contemplates rendering of a "service" to the payer of the fee. Mere collection of a "for use of a standard facility provided to all those willing to pay for it does not amount to the fee having been received for technical services

VODAFONE MOBILE SERVICES LTD.,,NEW DELHI vs. ITO, KARNAL

In the result, all the 03 Appeals i

Bench: Shri H.S. Sidhu & Shri Prashant Maharishi

251 ITR 53, wherein it has been held as under: "Technical service referred in section 9(1) (vii) contemplates rendering of a "service" to the payer of the fee. Mere collection of a "for use of a standard facility provided to all those willing to pay for it does not amount to the fee having been received for technical services

VODAFONE MOBILE SERVICES LTD.,,NEW DELHI vs. ITO, KARNAL

In the result, all the 03 Appeals i

Bench: Shri H.S. Sidhu & Shri Prashant Maharishi

251 ITR 53, wherein it has been held as under: "Technical service referred in section 9(1) (vii) contemplates rendering of a "service" to the payer of the fee. Mere collection of a "for use of a standard facility provided to all those willing to pay for it does not amount to the fee having been received for technical services

AMAZON WEB SERVICES, INC.,USA vs. ACIT, CIRCLE-1(1)(1), NEW DELHI

Accordingly, ground No. 3 along with its sub-grounds 3.1 to 3.4, ground No. 4 and ground No. 5 along with its sub-ground 5.1 r.w ground No. 2 are allowed

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

251, Little Falls Drive, Circle-1(1)(1) Wilmington Delaware, USA, New Delhi. USA 19808 PAN AATCA699SL (Appellant) (Respondent) Assessee by: Shri Porus Kaka, Sr. Advocate Shri Manish Kanth, Advocate Ms. Deepashree Rao, Advocate and Shri Hardeep Singh Chawla, Advocate Department by: Shri Vizay B. Vasanta, CIT-DR Date of Hearing: 03.05.2023 Date of 01.08.2023 pronouncement

AMAZON WEB SERVICES, INC.,USA vs. ACIT CIRCLE INTERNATIONAL TAX 1(1)(1), NEW DELHI

Accordingly, ground No. 3 along with its sub-grounds 3.1 to 3.4, ground No. 4 and ground No. 5 along with its sub-ground 5.1 r.w ground No. 2 are allowed

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

251, Little Falls Drive, Circle-1(1)(1) Wilmington Delaware, USA, New Delhi. USA 19808 PAN AATCA699SL (Appellant) (Respondent) Assessee by: Shri Porus Kaka, Sr. Advocate Shri Manish Kanth, Advocate Ms. Deepashree Rao, Advocate and Shri Hardeep Singh Chawla, Advocate Department by: Shri Vizay B. Vasanta, CIT-DR Date of Hearing: 03.05.2023 Date of 01.08.2023 pronouncement

EBNOY HOMES PVT. LTD.,NEW DELHI vs. ITO, WARD- 74(2), NEW DELHI

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

Bench: Shri R.K. Panda & Sh. Sudhanshu Srivastava

section 200A(1) by the Finance Act, 2015. Having considered the periods prior to 01.06.2015 & having upheld the validity of sec. 234E by Hon’ble High Courts, it can’t be said that the controversy, being raised now, has escaped the eyes of Hon’ble High Courts and therefore there can’t be any doubt that there is any iota

DCIT CIRCLE-12 (1) vs. GEO CONNECT LTD,

In the result, appeals filed by the assessee in ITA Nos

Bench: Sh. H.S. Sidhu & Sh. O.P. Kant

TDS on payment made to M/s IGTL amounting to Rs.40,29,614/- and failure in doing so ,the amount was disallowed under section 40(a)(i) of the Act. 9.8 Aggrieved with the disallowances, the assessee filed appeal before the first appellate authority and made elaborate submissions justifying no liability to deduct tax at source in case of payments

M/S GEO CONNECT LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, appeals filed by the assessee in ITA Nos

Bench: Sh. H.S. Sidhu & Sh. O.P. Kant

TDS on payment made to M/s IGTL amounting to Rs.40,29,614/- and failure in doing so ,the amount was disallowed under section 40(a)(i) of the Act. 9.8 Aggrieved with the disallowances, the assessee filed appeal before the first appellate authority and made elaborate submissions justifying no liability to deduct tax at source in case of payments