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90 results for “section 68”+ Section 194Jclear

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Key Topics

Section 20162Section 194J60Addition to Income58Section 143(3)55Section 201(1)48Disallowance46Section 4045Deduction42TDS39Section 263

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

section 194J of the Act. 2.3 On the facts and in the circumstances of the case and in law, the learned CIT(A)/TDS officer have erred in not appreciating that even as per the statement of technical 7 experts, the carriage of calls is an automatic activity and human intervention, if any, is required only at the stage

Showing 1–20 of 90 · Page 1 of 5

36
Section 194H21
Section 153C18

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

section 194J of the Act. 2.3 On the facts and in the circumstances of the case and in law, the learned CIT(A)/TDS officer have erred in not appreciating that even as per the statement of technical 7 experts, the carriage of calls is an automatic activity and human intervention, if any, is required only at the stage

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

section 194J of the Act. 2.3 On the facts and in the circumstances of the case and in law, the learned CIT(A)/TDS officer have erred in not appreciating that even as per the statement of technical 7 experts, the carriage of calls is an automatic activity and human intervention, if any, is required only at the stage

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

section 194J of the Act. 2.3 On the facts and in the circumstances of the case and in law, the learned CIT(A)/TDS officer have erred in not appreciating that even as per the statement of technical 7 experts, the carriage of calls is an automatic activity and human intervention, if any, is required only at the stage

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

section 194J of the Act. 2.3 On the facts and in the circumstances of the case and in law, the learned CIT(A)/TDS officer have erred in not appreciating that even as per the statement of technical 7 experts, the carriage of calls is an automatic activity and human intervention, if any, is required only at the stage

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

section 194J of the Act. 2.3 On the facts and in the circumstances of the case and in law, the learned CIT(A)/TDS officer have erred in not appreciating that even as per the statement of technical 7 experts, the carriage of calls is an automatic activity and human intervention, if any, is required only at the stage

VODAFONE IDEA LTD,NEW DELHI vs. ITO (TDS), KARNAL

The appeals of the Assessee are allowed

ITA 2467/DEL/2019[2011-12]Status: DisposedITAT Delhi20 Jan 2021AY 2011-12

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Appellant: Shri Deepak Chopra, Adv. & MsFor Respondent: Ms. Sulekha Verma, CIT-DR
Section 194HSection 201Section 201(1)

section 194J of the Act. 2.3 On the facts and in the circumstances of the case and in law, the learned CIT(A) have erred in not appreciating that even as per the statement of technical experts, the carriage of calls is an automatic activity and human intervention, if any, is required only at the stage of inter-connect

VODAFONE IDEA LTD. (EARLIER KNWON AS VODAFONE MOBILE SERVICES LTD.),NEW DELHI vs. ITO, TDS, KARNAL

The appeals of the Assessee are allowed

ITA 119/DEL/2019[2008-09]Status: DisposedITAT Delhi20 Jan 2021AY 2008-09

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Appellant: Shri Deepak Chopra, Adv. & MsFor Respondent: Ms. Sulekha Verma, CIT-DR
Section 194HSection 201Section 201(1)

section 194J of the Act. 2.3 On the facts and in the circumstances of the case and in law, the learned CIT(A) have erred in not appreciating that even as per the statement of technical experts, the carriage of calls is an automatic activity and human intervention, if any, is required only at the stage of inter-connect

VODAFONE IDEA LTD. (EARLIER KNWON AS VODAFONE MOBILE SERVICES LTD.),NEW DELHI vs. ITO, TDS, KARNAL

The appeals of the Assessee are allowed

ITA 120/DEL/2019[2009-10]Status: DisposedITAT Delhi20 Jan 2021AY 2009-10

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Appellant: Shri Deepak Chopra, Adv. & MsFor Respondent: Ms. Sulekha Verma, CIT-DR
Section 194HSection 201Section 201(1)

section 194J of the Act. 2.3 On the facts and in the circumstances of the case and in law, the learned CIT(A) have erred in not appreciating that even as per the statement of technical experts, the carriage of calls is an automatic activity and human intervention, if any, is required only at the stage of inter-connect

VODAFONE IDEA LTD. (EARLIER KNWON AS VODAFONE MOBILE SERVICES LTD.),NEW DELHI vs. ITO, TDS, KARNAL

The appeals of the Assessee are allowed

ITA 118/DEL/2019[2007-08]Status: DisposedITAT Delhi20 Jan 2021AY 2007-08

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Appellant: Shri Deepak Chopra, Adv. & MsFor Respondent: Ms. Sulekha Verma, CIT-DR
Section 194HSection 201Section 201(1)

section 194J of the Act. 2.3 On the facts and in the circumstances of the case and in law, the learned CIT(A) have erred in not appreciating that even as per the statement of technical experts, the carriage of calls is an automatic activity and human intervention, if any, is required only at the stage of inter-connect

VODAFONE IDEA LTD,NEW DELHI vs. ITO (TDS), KARNAL

The appeals of the Assessee are allowed

ITA 2466/DEL/2019[2010-11]Status: DisposedITAT Delhi20 Jan 2021AY 2010-11

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Appellant: Shri Deepak Chopra, Adv. & MsFor Respondent: Ms. Sulekha Verma, CIT-DR
Section 194HSection 201Section 201(1)

section 194J of the Act. 2.3 On the facts and in the circumstances of the case and in law, the learned CIT(A) have erred in not appreciating that even as per the statement of technical experts, the carriage of calls is an automatic activity and human intervention, if any, is required only at the stage of inter-connect

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)

194J of the Act. Therefore, we reverse the order of the ld CIT(A) and assessee’s appeal is allowed on this ground also.” 31. The AO as well as the Ld. CIT(A) has recorded that there is no human intervention when the call is successfully completed. It is also not disputed that there is no difference

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)

194J of the Act. Therefore, we reverse the order of the ld CIT(A) and assessee’s appeal is allowed on this ground also.” 31. The AO as well as the Ld. CIT(A) has recorded that there is no human intervention when the call is successfully completed. It is also not disputed that there is no difference

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)

194J of the Act. Therefore, we reverse the order of the ld CIT(A) and assessee’s appeal is allowed on this ground also.” 31. The AO as well as the Ld. CIT(A) has recorded that there is no human intervention when the call is successfully completed. It is also not disputed that there is no difference

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 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)

194J of the Act. Therefore, we reverse the order of the ld CIT(A) and assessee’s appeal is allowed on this ground also.” 31. The AO as well as the Ld. CIT(A) has recorded that there is no human intervention when the call is successfully completed. It is also not disputed that there is no difference

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)

194J of the Act. Therefore, we reverse the order of the ld CIT(A) and assessee’s appeal is allowed on this ground also.” 31. The AO as well as the Ld. CIT(A) has recorded that there is no human intervention when the call is successfully completed. It is also not disputed that there is no difference

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)

194J of the Act. Therefore, we reverse the order of the ld CIT(A) and assessee’s appeal is allowed on this ground also.” 31. The AO as well as the Ld. CIT(A) has recorded that there is no human intervention when the call is successfully completed. It is also not disputed that there is no difference

M/S BHARTI HEXACOM LTD.,,NEW DELHI vs. ACIT, NEW DELHI

In the result, assessee’s appeals are allowed and department’s appeal dismissed

ITA 3394/DEL/2012[2008-09]Status: DisposedITAT Delhi21 Apr 2016AY 2008-09

Bench: Shri S.V. Mehrotra: & Shri A.T. Varkey:

For Appellant: Shri Anil Bhalla CA &For Respondent: Shri A.K. Saroha CIT (DR)
Section 115JSection 194HSection 194JSection 234BSection 35ASection 40Section 54

194J are not applicable, therefore, for the reasoning given for ground nos. 1 & 1.1, the assessee’s both grounds are allowed. ITA no. 2795/Del/2012 (Revenue’s appeal): 49. The department has raised following grounds of appeal: “1. The Ld. CIT(A) has erred on facts and in law in deleting addition of Rs.75,82,37,380/- made

M/S AT & T GLOBAL BETWORK SERVICES (INDIA) PVT. LTD.,,GURGAON vs. DCIT, NEW DELHI

In the result, the appeal of assessee in ITA No

ITA 4882/DEL/2013[2008-09]Status: DisposedITAT Delhi10 May 2019AY 2008-09

Bench: Shri N.K. Billaiya & Shri Kuldip Singh[A.Y 2008-09] At &T Global Network Services [India] Vs. The Dy. C.I.T Pvt Ltd, Vatika Triangle Circle - 2 (1) 3Rd Floor, Sushant Lok - I New Delhi Block A, Gurgaon Pan: Aafca 8810 L [A.Y 2008-09] The Dy. C.I.T Vs. At &T Global Network Services Circle 2(1) [India] Pvt Ltd, Vatika Triangle 3Rd Floor, Sushant Lok - I New Delhi Block A, Gurgaon Pan: Aafca 8810 L (Applicant) (Respondent) Assessee By : Shri Kanchan Kaushal, Adv Ms. Chinu Bhasin, Ca Department By : Shri H.K. Choudhary, Cit-Dr

For Appellant: Shri Kanchan Kaushal, AdvFor Respondent: Shri H.K. Choudhary, CIT-DR
Section 143(3)Section 144CSection 144C(1)Section 153Section 234B

194J but was actually deducted under section 194C, such a deduction would not meet the requirements of section 40(a)(ia). We noted that prior to this decision the Hon'ble Calcutta High Court in the case of CIT vs. S.K. Tekriwal 361 ITR 432 vide order dated 3rd December, 2014 taken a view by which

DURGESH AUTOFIN P.LTD,BIJNOR vs. PRCIT, MUZAFFARNAGAR

In the result, the appeal of the assessee is allowed

ITA 2539/DEL/2018[2013-14]Status: DisposedITAT Delhi09 Oct 2018AY 2013-14

Bench: Sh. N. K. Saini, Am & Ms. Suchitra Kamble, Jm Ita No. 2539/Del/2018 : Asstt. Year : 2013-14 Durgesh Autofin P. Ltd., Vs Pr. Commissioner Of Income Tax, C/O Sh. Pankaj Kumar, Director, Muzaffarnagar-251002 S/O Late Sh. Tejpal Singh, Mandi Kotla, Near Nehru Murti, Chandpur, Bijnot, Bijnor, Uttar Pradesh (Appellant) (Respondent) Pan No. Aaccd0768P Assessee By : Sh. Vivek Bansal, Adv. Revenue By : Ms. Rachna Singh, Cit Dr Date Of Hearing : 29.08.2018 Date Of Pronouncement : 09.10.2018 Order Per N. K. Saini, Am: This Is An Appeal By The Assessee Against The Order Dated 13.03.2018 Of Ld. Pr. Cit, Muzaffarnagar U/S 263 Of The Income Tax Act, 1961 (Hereinafter Referred To As The Act).

For Appellant: Sh. Vivek Bansal, AdvFor Respondent: Ms. Rachna Singh, CIT DR
Section 143(3)Section 263Section 269SSection 271DSection 41(1)Section 68

68 of the Act. In the present case, it is an admitted fact that the ld. Pr. CIT exercised his revisionary powers u/s 263 of the Act, the said power may be summarized as under: "(i) The CIT must record satisfaction that the order of the AO is erroneous and prejudicial to the interests of the Revenue. Both the conditions