VODAFONE SOUTH LIMITED Vs. DEPUTY DIRECTOR OF INCOME TAX INTERNATIONAL TAXATION

JUDGEMENT

(1.) Petitioner, a company incorporated under the provisions of the Companies Act, 1956, and a subsidiary of M/s Vodafone Mobile Services Limited, engaged in the business of providing telecom services to its subscribers in India, has brought in question the order of the Income Tax Appellate Tribunal, Bangalore Bench, (hereinafter referred to as ITAT, for brevity) dated 6.3.2014 (vide Annexure-G) on two interlocutory applications filed by it in No.63- 67/Bang/2013 and has sought a writ of prohibition or such other writ to direct the respondents not to enforce the assessment order passed by the respondent herein vide Annexure-A dated 28.1.2013 and the consequent demand notice in pursuance to Annexure-A vide Annexure-B on the same day.

(2.) On issuance of notice regarding Rule, Mr.K.V.Arvind has entered appearance for the Revenue.

(3.) I have heard persuasive arguments of Mr.Abhishek Manu Singhvi, learned advocate for the petitioner and also Mr.K.V.Aravind, standing counsel for the Revenue-Income Tax Department and perused records in supplementation thereto from which the following factual matrix manifests and is relevant for consideration: