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391 results for “TDS”+ Section 251(1)(a)clear

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Key Topics

Section 143(3)52Section 4050Deduction50TDS47Addition to Income41Disallowance30Section 194J24Section 194C21Section 6817Section 250

DCIT, CIRCLE 22(2), NEW DELHI, NEW DELHI vs. SAHIL VACHANI, DELHI

Appeal of the Revenue stands dismissed

ITA 2604/DEL/2023[2016-17]Status: DisposedITAT Delhi23 Jun 2025AY 2016-17

Bench: Shri Mahavir Singh, Vice Presdient (), Shri Vikas Awasthy& Shriavdhesh Kumar Mishraआअसं.2604/िद"ी/2023(िन.व. 2016-17)

For Appellant: S/Shri Anuj Garg & Narpat Singh, Sr.DRFor Respondent: S/Shri Rohan Khare & Priyam
Section 271(1)(c)Section 54F

251 ITR 99affirmed the decision of the Kerala High Court. The Kerala High Court observed as follows: "Section 271(1)(c) of the Income-tax Act, 1961, is attracted where, in the course of any proceedings under the Act, the Assessing Officer or the first appellate authority is satisfied that: (a) any person has concealed the particulars of his income

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

Showing 1–20 of 391 · Page 1 of 20

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16
Double Taxation/DTAA16
Section 26315
ITA 4077/DEL/2012[2009-10 (F.Y. 2008-09)]Status: DisposedITAT Delhi17 Mar 2016

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

For Appellant: Sh. S.K. Tulsiyan, Adv., ShFor Respondent: Sh. Anuj Arora, CIT(DR)
Section 194JSection 201Section 201(1)Section 9Section 9(1)(vii)

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

ITA 3595/DEL/2012[2010-11 (F.Y. 2009-10)]Status: DisposedITAT Delhi17 Mar 2016

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

For Appellant: Sh. S.K. Tulsiyan, Adv., ShFor Respondent: Sh. Anuj Arora, CIT(DR)
Section 194JSection 201Section 201(1)Section 9Section 9(1)(vii)

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

ITA 3596/DEL/2012[2011-12 (F.Y. 2010-11)]Status: DisposedITAT Delhi17 Mar 2016

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

For Appellant: Sh. S.K. Tulsiyan, Adv., ShFor Respondent: Sh. Anuj Arora, CIT(DR)
Section 194JSection 201Section 201(1)Section 9Section 9(1)(vii)

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

ITA 3594/DEL/2012[2009-10 (F.Y. 2008-09)]Status: DisposedITAT Delhi17 Mar 2016

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

For Appellant: Sh. S.K. Tulsiyan, Adv., ShFor Respondent: Sh. Anuj Arora, CIT(DR)
Section 194JSection 201Section 201(1)Section 9Section 9(1)(vii)

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

ITA 3593/DEL/2012[2008-09 (F.Y. 2007-08)]Status: DisposedITAT Delhi17 Mar 2016

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

For Appellant: Sh. S.K. Tulsiyan, Adv., ShFor Respondent: Sh. Anuj Arora, CIT(DR)
Section 194JSection 201Section 201(1)Section 9Section 9(1)(vii)

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

ITA 4076/DEL/2012[2008-09 (F.Y. 2007-08)]Status: DisposedITAT Delhi17 Mar 2016

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

For Appellant: Sh. S.K. Tulsiyan, Adv., ShFor Respondent: Sh. Anuj Arora, CIT(DR)
Section 194JSection 201Section 201(1)Section 9Section 9(1)(vii)

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

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

In the result, all the 03 Appeals i

ITA 716/DEL/2017[2007-08]Status: DisposedITAT Delhi07 Nov 2017AY 2007-08

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

For Appellant: Sh. Salil Kapoor & Ms. Ananya KapoorFor Respondent: Sh. S.S. Rana, CIT(DR)
Section 194JSection 201Section 201(3)Section 250(6)Section 263

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

ITA 3781/DEL/2013[2009-10 (F.Y. 2008-09)]Status: DisposedITAT Delhi07 Nov 2017

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

For Appellant: Sh. Salil Kapoor & Ms. Ananya KapoorFor Respondent: Sh. S.S. Rana, CIT(DR)
Section 194JSection 201Section 201(3)Section 250(6)Section 263

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

ITA 3779/DEL/2013[2007-08 (F.Y. 2006-07)]Status: DisposedITAT Delhi07 Nov 2017

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

For Appellant: Sh. Salil Kapoor & Ms. Ananya KapoorFor Respondent: Sh. S.S. Rana, CIT(DR)
Section 194JSection 201Section 201(3)Section 250(6)Section 263

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

ITA 717/DEL/2017[2008-09]Status: DisposedITAT Delhi07 Nov 2017AY 2008-09

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

For Appellant: Sh. Salil Kapoor & Ms. Ananya KapoorFor Respondent: Sh. S.S. Rana, CIT(DR)
Section 194JSection 201Section 201(3)Section 250(6)Section 263

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

ITA 718/DEL/2017[2009-10]Status: DisposedITAT Delhi07 Nov 2017AY 2009-10

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

For Appellant: Sh. Salil Kapoor & Ms. Ananya KapoorFor Respondent: Sh. S.S. Rana, CIT(DR)
Section 194JSection 201Section 201(3)Section 250(6)Section 263

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

ITA 3780/DEL/2013[2008-09 (F.Y. 2007- 08)]Status: DisposedITAT Delhi07 Nov 2017

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

For Appellant: Sh. Salil Kapoor & Ms. Ananya KapoorFor Respondent: Sh. S.S. Rana, CIT(DR)
Section 194JSection 201Section 201(3)Section 250(6)Section 263

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 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

ITA 523/DEL/2023[2016-17]Status: FixedITAT Delhi01 Aug 2023AY 2016-17

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

For Appellant: Shri Porus Kaka, Sr. AdvocateFor Respondent: Shri Vizay B. Vasanta, CIT-DR
Section 144CSection 147Section 151Section 201Section 9(1)(vi)

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-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

ITA 522/DEL/2023[2014-15]Status: FixedITAT Delhi01 Aug 2023AY 2014-15

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

For Appellant: Shri Porus Kaka, Sr. AdvocateFor Respondent: Shri Vizay B. Vasanta, CIT-DR
Section 144CSection 147Section 151Section 201Section 9(1)(vi)

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

ITA 1101/DEL/2018[2015-16]Status: DisposedITAT Delhi31 Aug 2020AY 2015-16

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

Section 200Section 200ASection 200A(1)Section 234Section 234ESection 271Section 271H

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

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

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

ITA 127/DEL/2011[2003-04]Status: DisposedITAT Delhi17 Jan 2017AY 2003-04

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

Section 143(2)Section 143(3)Section 195Section 271(1)(c)Section 9(1)(vii)

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

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

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

ITA 1927/DEL/2008[2002-2003]Status: DisposedITAT Delhi17 Jan 2017AY 2002-2003

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

Section 143(2)Section 143(3)Section 195Section 271(1)(c)Section 9(1)(vii)

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

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

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

ITA 2088/DEL/2008[2002-2003]Status: DisposedITAT Delhi17 Jan 2017AY 2002-2003

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

Section 143(2)Section 143(3)Section 195Section 271(1)(c)Section 9(1)(vii)

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

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

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

ITA 5851/DEL/2011[2002-03]Status: DisposedITAT Delhi17 Jan 2017AY 2002-03

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

Section 143(2)Section 143(3)Section 195Section 271(1)(c)Section 9(1)(vii)

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