TMI Blog2019 (9) TMI 1205X X X X Extracts X X X X X X X X Extracts X X X X ..... l services are given as there is absence of any human intervention in providing it. On the other hand, the Revenue has placed reliance upon the evidence of the technical expert in the case of Vodafone Essar Mobile Services Ltd. (supra) to canvass the view that even in the present facts that the technical services are rendered. Thus, requiring deduction of tax u/s 194J of the Act. We asked Mr. Sure ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n order dated 27th May, 2016 passed by the Income Tax Appellate Tribunal (Tribunal) for Assessment Years 2009-10, 2010-11, 2011-12 and 2012-13. 2. The Revenue has urged the following identical questions of law for our consideration :- (a) Whether on the facts and in the circumstances of the case and in law, the Tribunal is correct in holding that the relationship bet ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... liable for TDS under Section 194J of the I.T. Act, 1961? 3. We heard the parties fully on question nos. (a) and (b) above. We did inform them that we were inclined to admit admit question nos. (a) and (b) for consideration as they do give rise to substantial question of law. However, as the appeal is being adjourned on account of question (c), we have not passed any order admittin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ked Mr. Suresh Kumar, whether the decision of the Calcutta Bench of the Tribunal in the case of Vodafone Essar Mobile Services Ltd. (supra) has been accepted by the Revenue or any appeal has been filed by the Revenue and if so, the result thereof. Mr. Suresh Kumar, seeks time of two weeks to enable him to take appropriate instructions. 5. Accordingly, these appeals are adjourned to ..... X X X X Extracts X X X X X X X X Extracts X X X X
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