VODAFONE IDEA LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-14(2), HYDERABAD
In the result, the appeals and cross objections of the assessee for the Asst Years 2002-03 and 2003-04 are allowed and appeals of the revenue are dismissed
ITA 1913/HYD/2019[2004-05]Status: DisposedITAT Hyderabad05 May 2022AY 2004-05
Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu
For Appellant: Shri Ronak DoshiFor Respondent: Shri Rajendra Kumar(CIT-DR)
Section 133ASection 194HSection 194JSection 201(1)Section 9
194J read with Explanation 2(iva) to section 9( I )(vi) of the Act. For ease of reference same is reproduced as under:
"Explanation 2.-For the purposes of this clause,
"royalty" means consideration (including any lump sum consideration but excluding any consideration which would be the income of the recipient chargeable under the head "Capital gains
