TATA TELESERVICES LTD.,NOIDA vs. ACIT, CIRCLE- 25(1), NEW DELHI

Accordingly, this issue is raised in grounds of appeal No.4 of the Revenue in all these years is dismissed

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.5665/Del/2019 (Assessment Year 2012-13)

penalty proceedings under section 271(1)(c) of the Act. The above grounds of appeal are mutually exclusive & without prejudice to each other. The Appellant prays for leave to add, alter, amend or modify any of the grounds of appeal at or before the erring of the appeal. The Appellant prays for appropriate relief based on the said grounds

TATA TELESERVICES LTD.,NEW DELHI vs. DCIT, CIRCLE-25(1), NEW DELHI

Accordingly, this issue is raised in grounds of appeal No.4 of the Revenue in all these years is dismissed

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.5665/Del/2019 (Assessment Year 2012-13)

penalty proceedings under section 271(1)(c) of the Act. The above grounds of appeal are mutually exclusive & without prejudice to each other. The Appellant prays for leave to add, alter, amend or modify any of the grounds of appeal at or before the erring of the appeal. The Appellant prays for appropriate relief based on the said grounds

DCIT CIRCLE 25(1), NEW DELHI vs. TATA TELESERVICES LTD., NEW DELHI

Accordingly, this issue is raised in grounds of appeal No.4 of the Revenue in all these years is dismissed

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.5665/Del/2019 (Assessment Year 2012-13)

penalty proceedings under section 271(1)(c) of the Act. The above grounds of appeal are mutually exclusive & without prejudice to each other. The Appellant prays for leave to add, alter, amend or modify any of the grounds of appeal at or before the erring of the appeal. The Appellant prays for appropriate relief based on the said grounds

DCIT CIRCLE 25(1), NEW DELHI vs. TATA TELESERVICES LTD., NEW DELHI

Accordingly, this issue is raised in grounds of appeal No.4 of the Revenue in all these years is dismissed

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.5665/Del/2019 (Assessment Year 2012-13)

penalty proceedings under section 271(1)(c) of the Act. The above grounds of appeal are mutually exclusive & without prejudice to each other. The Appellant prays for leave to add, alter, amend or modify any of the grounds of appeal at or before the erring of the appeal. The Appellant prays for appropriate relief based on the said grounds

DCIT CIRCLE - 25(1), NEW DELHI vs. TATA TELESERVICES LTD.,, NEW DELHI

Accordingly, this issue is raised in grounds of appeal No.4 of the Revenue in all these years is dismissed

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.5665/Del/2019 (Assessment Year 2012-13)

penalty proceedings under section 271(1)(c) of the Act. The above grounds of appeal are mutually exclusive & without prejudice to each other. The Appellant prays for leave to add, alter, amend or modify any of the grounds of appeal at or before the erring of the appeal. The Appellant prays for appropriate relief based on the said grounds

DCIT CIRCLE - 25(1), NEW DELHI vs. TATA TELESERVICES LTD.,, NEW DELHI

Accordingly, this issue is raised in grounds of appeal No.4 of the Revenue in all these years is dismissed

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.5665/Del/2019 (Assessment Year 2012-13)

penalty proceedings under section 271(1)(c) of the Act. The above grounds of appeal are mutually exclusive & without prejudice to each other. The Appellant prays for leave to add, alter, amend or modify any of the grounds of appeal at or before the erring of the appeal. The Appellant prays for appropriate relief based on the said grounds

TATA TELESERVICES LTD.,,NEW DELHI vs. ACIT CIRCLE - 25(1), NEW DELHI

Accordingly, this issue is raised in grounds of appeal No.4 of the Revenue in all these years is dismissed

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.5665/Del/2019 (Assessment Year 2012-13)

penalty proceedings under section 271(1)(c) of the Act. The above grounds of appeal are mutually exclusive & without prejudice to each other. The Appellant prays for leave to add, alter, amend or modify any of the grounds of appeal at or before the erring of the appeal. The Appellant prays for appropriate relief based on the said grounds

TATA TELESERVICES LTD.,,NEW DELHI vs. ACIT CIRCLE - 25(1), NEW DELHI

Accordingly, this issue is raised in grounds of appeal No.4 of the Revenue in all these years is dismissed

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.5665/Del/2019 (Assessment Year 2012-13)

penalty proceedings under section 271(1)(c) of the Act. The above grounds of appeal are mutually exclusive & without prejudice to each other. The Appellant prays for leave to add, alter, amend or modify any of the grounds of appeal at or before the erring of the appeal. The Appellant prays for appropriate relief based on the said grounds

ACIT CIRCLE 25(1) , DELHI vs. TATA TELESERVICES LTD. , DELHI

Accordingly, this issue is raised in grounds of appeal No.4 of the Revenue in all these years is dismissed

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.5665/Del/2019 (Assessment Year 2012-13)

penalty proceedings under section 271(1)(c) of the Act. The above grounds of appeal are mutually exclusive & without prejudice to each other. The Appellant prays for leave to add, alter, amend or modify any of the grounds of appeal at or before the erring of the appeal. The Appellant prays for appropriate relief based on the said grounds

VODAFONE IDEA LTD. (EARLIER KNWON AS VODAFONE MOBILE SERVICES LTD.),MUMBAI vs. ACIT,. CIRCLE-26(2), NEW DELHI

In the result, all above said grounds are allowed for statistical purpose

Bench: Shri S. Rifaur Rahman & Shriyogesh Kumar U.S.Vodafone Idea Ltd Vs. Acit, (Earlier Known As Vodafone Circle-26(2), Mobile Services Ltd) New Delhi 10Th Floor, Birla Centurion, Century Mills Compound, Pandurang Budhkar Marg, Worli, Mumbai, Maharastra (Appellant) (Respondent) Pan: Aaacb2100P

194H of the Act, alleging the same to be in the nature of commission. 9.3 The ld DRP upheld the action of the ld AO. 9.4 The ld counsel for the assessee submitted that this issue is squarely covered in favour of the assessee and relied on the following decisions:- a. Bharti Cellular Ltd. v/s. A CIT reported

TATA TELESERVICES LTD.,,NEW DELHI vs. ACIT CIRCLE - 25(1), NEW DELHI

penalty proceedings under section 271(1)(c) of the Act.\nThe above grounds of appeal are mutually exclusive & without prejudice to\neach other. The Appellant prays for leave to add, alter, amend or modify any\nof the grounds of appeal at or before the erring of the appeal.\nThe Appellant prays for appropriate relief based on the said grounds

M/S. UNITECH WIRELESS (TAMILNADU) PVT. LTD.,,GURGAON vs. ACIT, NEW DELHI

In the result, the ground of appeal raised by the revenue is allowed for statistical purpose

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

194H of the Act. ITA Nos. 2355, 2356, 2925 & 11 2926/Del/2015 Unitech Wireles Tamil Nadu Pvt. Ltd. Therefore, the addition raised is confirmed and the ground of appeals dismissed. 8. Having gone through the order of the ld. CIT(A) and after hearing the arguments of the assessee and also after going through the different clauses of the agreement which

ACIT, DELHI vs. M/S. UNITECH WIRELESS TAMILNADU PVT. LTD., NEW DELHI

In the result, the ground of appeal raised by the revenue is allowed for statistical purpose

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

194H of the Act. ITA Nos. 2355, 2356, 2925 & 11 2926/Del/2015 Unitech Wireles Tamil Nadu Pvt. Ltd. Therefore, the addition raised is confirmed and the ground of appeals dismissed. 8. Having gone through the order of the ld. CIT(A) and after hearing the arguments of the assessee and also after going through the different clauses of the agreement which

ACIT, DELHI vs. M/S. UNITECH WIRELESS TAMILNADU PVT. LTD., NEW DELHI

In the result, the ground of appeal raised by the revenue is allowed for statistical purpose

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

194H of the Act. ITA Nos. 2355, 2356, 2925 & 11 2926/Del/2015 Unitech Wireles Tamil Nadu Pvt. Ltd. Therefore, the addition raised is confirmed and the ground of appeals dismissed. 8. Having gone through the order of the ld. CIT(A) and after hearing the arguments of the assessee and also after going through the different clauses of the agreement which

M/S. UNITECH WIRELESS (TAMILNADU) PVT. LTD.,,GURGAON vs. ACIT, NEW DELHI

In the result, the ground of appeal raised by the revenue is allowed for statistical purpose

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

194H of the Act. ITA Nos. 2355, 2356, 2925 & 11 2926/Del/2015 Unitech Wireles Tamil Nadu Pvt. Ltd. Therefore, the addition raised is confirmed and the ground of appeals dismissed. 8. Having gone through the order of the ld. CIT(A) and after hearing the arguments of the assessee and also after going through the different clauses of the agreement which

DCIT CIRCLE-4(2), NEW DELHI vs. BHARTI HEXACOM LTD., DELHI

In the result, the appeals of the revenue are partly allowed as indicated above

Bench: Shri C.N. Prasad & Shri M. Balaganesh

194H of the Act by treating the said amount as commission expenses. 7. On appeal the learned CIT(A) following the decision of the Hon’ble Delhi High Court in assessee’s own case for the A.Ys. 2003-04 to 2009-10 deleted the license fee and spectrum charges which are amortized by the AO u/s. 35ABB, and allowed

DCIT CIRCLE 4(2), NEW DELHI vs. BHARTI HEXACOM LTD., DELHI

In the result, the appeals of the revenue are partly allowed as indicated above

Bench: Shri C.N. Prasad & Shri M. Balaganesh

194H of the Act by treating the said amount as commission expenses. 7. On appeal the learned CIT(A) following the decision of the Hon’ble Delhi High Court in assessee’s own case for the A.Ys. 2003-04 to 2009-10 deleted the license fee and spectrum charges which are amortized by the AO u/s. 35ABB, and allowed

DCIT CIRCLE 4(2), NEW DELHI vs. BHARTI HEXACOM LTD., DELHI

In the result, the appeals of the revenue are partly allowed as indicated above

Bench: Shri C.N. Prasad & Shri M. Balaganesh

194H of the Act by treating the said amount as commission expenses. 7. On appeal the learned CIT(A) following the decision of the Hon’ble Delhi High Court in assessee’s own case for the A.Ys. 2003-04 to 2009-10 deleted the license fee and spectrum charges which are amortized by the AO u/s. 35ABB, and allowed