CiteTEXT
...Cit v. At & T Communication Services India Pvt. Ltd.(342 ITR 257) (Delhi).4. We have carefully considered the contentions of the ld. DR...decision of the Hon'ble Delhi High Court in the case of AT&T Communication Services India (P) Ltd. (supra). In both the cases, it has been held that u/s 40(a)(ia) of the Act for non deduction of tax at...raised the issue of deletion of penalty of Rs. 84,69,053/- levied under section 271(1)(c) of the Income Tax Act, 1961.2. At the outset, we would like to mention here that neither the...
...
IN THE MATTER OF :
AT & T COMMUNICATION SERVICES INDIA PVT.LTD. ..... Plaintiff Through: Mr.Vijay Kumar, Advocate
versus...
* IN THE HIGH COURT OF DELHI AT NEW DELHI + CS(OS) 1087/2013
Decided on 24.04.2015...parties have arrived at an out of court settlement in terms whereof, the plaintiff has received the principal amount from the defendant and has relinquished the rest of its claim raised in the suit. The...
...Year 2012-13 DCIT, v. AT & T Communication Services Circle-3(2), India Pvt. Ltd., New Delhi. New Delhi.
TAN/PAN: AACCA8033E
(Appellant) (Respondent...
O R D E R
PER PRADIP KUMAR KEDIA, A.M.:
The captioned appeal has been filed at the instance of the Revenue against the order of.... Section 143(3) of the Income Tax Act, 1961 (the Act) concerning AY 2012-13.
2. When the matter was called for hearing, the ld. counsel for the assessee at the outset submitted...
...)
Assessment Years: 2015-16 AT & T Communication Services Vs. ACIT India Pvt. Ltd., Circle-3(2), Vatika Triangle, 3rdFloor, New Delhi. Sushant Lok-1, Block-A,
Gurgaon...
...building. If that be so, I find that the decisions of this Tribunal in the case of M/s. AT & T Communication Services India Pvt. Limited - 2007 (219) ELT 461 (Tri.), Nova...
...Section 142(2A) of the Income Tax Act, 1961 for the assessment year 2008-2009.2. The petitioner is a wholly owned subsidiary of AT & T Communication Services Internation...concerned, the terms of reference for special audit were as follows:“(ii) AT & T Communication Services India Pvt. Ltd..Related party transactions with AT & T...) AT & T Communication Services India Pvt. Ltd..Brief Facts: (Annexure “E”)The related party transactions relates to sale of Service Income; the Net Income is reported...
...company of the AT & T group of companies. Globally, it has operating divisions focussed on Business Solutions, Entertainment, Consumer Mobility, and International. In India, it is stated to have five affiliates, namely, AT ...India Private Limited (“ACSI”), AT & T Global Business Services India Private Limited...management services to support AT & T and its customers under appropriate authorisations from DOT. It has been stated that it substantially provides captive services. AGBSI is stated to provide network...
...AT & T Communication Services India Pvt. Ltd. v. CC, Bangalore reported in (Tri.-Bang.) it was held that the mistake committed by the courier in serving appeal papers to office of...rightly addressed to Commissioner (Appeals), were wrongly dispatched by them to Commissioner of Customs, Kandla. The said appeals were dispatched by the Courier Blue Dart and were duly received at Kandla...that the impugned orders were passed by the Adjudicating Authority in de-novo proceedings and the appellants have been diligently following the proceedings at all the levels. In support of his...
.... 16.64 crores subject to payment of Rs. 3.50 crores AT & T COMMUNICATION SERVICES INDIA PVT. LTD., GURGAON vs DCIT Circle-3(2) New Delhi (Appellant) (Respondent) S.A.No.-71...in terms indicated above. The order is pronounced in the open court at the time of hearing itself i.e. on 09.02.2018. Sd/- Sd/- (KULDIP SINGH) (R.K. PANDA) JUDICIAL MEMBER ACCOUNTANT MEMBER *NEHA...
...paid to AT&T Communication Services India Private Limited ('ACSI'). 5.2 On the facts in the circumstances of the case and in law, the Hon'ble DRP erred in ignoring that the aforesaid disallowance on...appellant has incurred support service expenditure AT & T Global Network Services ( India) Pvt Ltd Vs DCIT , Circle -2 (1) New Delhi ITA No. 292 /Del/2016 ( Assessee) A Y 2011-12 ...customers of its Associated Enterprises (AEs). For rendering such services, it availed certain services from its AE [i.e. AT&T Communication Services International Inc., U.S.A.] in the nature of I...
...:-“Whether the ITAT was right in law in upholding the decision of the CIT(A) deleting the penalty levied for assessment year 2006-07 who has relied upon the decision of ITAT Delhi in AT&T Communication ...learned CIT(Appeals) considering the material on record correctly followed the decision of the Delhi Bench in the case of AT&T Communications Services (India) Pvt. Limited (supra) for cancelling the...Commissioner Of Income Tax v. Zoom Communication Pvt Ltd S (2010) 327 ITR 510?”2. A few facts relevant for the decision of the...
...
DCIT, Circle 3(2), vs. AT & T Communication Services (India) New Delhi. Pvt. Ltd., Mohan Dev House,
13, Tolstoy Marg, New Delhi...passed by the Commissioner of Income Tax (Appeals)-I, New Delhi ("Ld. CIT(A)") for the assessment year 2004-05, in the case of AT & T Communication Services (India) Pvt. Ltd.("the assessee"), the Revenue...preferred this appeal.
2. Brief facts of the case are that the assessee company is engaged in the business of network design, management, communication, connectivity services and...
...AT & T Communication Services India Pvt. Ltd. v. CC, Bangalore reported in (Tri.-Bang.) it was held that the mistake committed by the courier in serving appeal papers to office of...rightly addressed to Commissioner (Appeals), were wrongly dispatched by them to Commissioner of Customs, Kandla. The said appeals were dispatched by the Courier Blue Dart and were duly received at Kandla...that the impugned orders were passed by the Adjudicating Authority in de-novo proceedings and the appellants have been diligently following the proceedings at all the levels. In support of his...
.... Ltd. 322 ITR 158 (S.C)2) Cit v. At & T Communication Services India Pvt. Ltd. 342 ITR..., but it wholly depends upon the conduct of the assessee, whether at all, there was a hint of concealment in the case. We have gone through the accounts of the assessee and we find that during the year...
...office of the Commissioner (Appeals), hence there is no delay in filing the appeal. The appellant also relied upon the decisions of the Tribunal in the case of AT & T Communication Services India Pvt...
...relied upon the decisions of the Tribunal in the case of AT & T Communication Services India Pvt. Ltd. Vs. CC, Bangalore reported in 2007 (219) ELT 461 and...
...nature of support service expenses of Rs. 13,42,85,216 paid to AT&T Communication Services India Private Limited (‘ACSI’).5.2 On the facts in the circumstances of the case and in law...Disallowance of Support Service expenditure. The appellant has incurred support service expenditure of Rs. 13,42,85,216 paid to its group company i.e. AT&T Communication Services India Private Limited...network connectivity services to customers of its Associated Enterprises (‘AEs’). For rendering such services, it availed certain services from its AE [i.e. AT&T Communication Services In...
...decision in case of Cit v. At & T Communication Services India Pvt. Ltd.. ltd. — (Supra) as also the decision in cases cited by Ld. A.R and...deposited tax at source on 23.01.2008 only after the order of the A.O u/s. 143(3) to defend penalty proceedings.”3. We have heard rival submissions and gone through facts and circumstances...of the case. We find that the assessee company has not deducted TDS u/s. 194-C of the Act on transportation hire charges i.e freight payment at Rs. 11,49,562/-. The contention of the assessee before...
...examined the precedent of Hon'ble High Court of Delhi in the case of IT vs. AT & T Communication Services India Pvt.Ltd...assessee was authorized to pay a sum of Rs.29,10,064/- to M/s.Dhananjay Housing Ltd. subject to deduction at source @ 1% and Surcharge/Education Cess as applicable thereon. So, the AO has held that on...)/Certificate/DHL/2007- 08 dated 31.03.2008 vide a certificate issued u/s.197(1) of the Act to pay only a sum of Rs.29,10,064/- after deducting the income-tax at source @ 1%. So, the AO had raised a question that...
...deletion of penalty under section 271 (1) (C) was confirmed. Further the Honble Delhi High Court in AT&T communication services India private limited 18 Taxmann.com 14 for (Delhi) has further affirmed...addition of Rs. 2 448519/ was made on account of non-deduction of tax at source on payment made to bonded warehouse charges of Rs. 2 359632/ and professional in legal fees of Rs. 88887/. Hence assessment...losses and therefore there cannot be any reason to evade any tax. It was further stated that penalty cannot be imposed if the assessee has failed to deduct tax at source. It was further stated that it is...