The Commissioner Of Income-Tax ... vs Vodafone Cellular Ltd,

ik-42853881 Bombay High Court 5 March 2026 • 5 min read

Judges (2)

Counsel (4)

Parties (2)

Case Significance

The Commissioner Of Income-Tax ... vs Vodafone Cellular Ltd, is a Bombay High Court decision dated March 5, 2026 (citation: ik-42853881). The CIT (TDS) appealed a Tribunal order holding that Section 201(1) proceedings against Vodafone for the first three quarters of AY 2009-10 were time-barred under Section 201(3) of the Income Tax Act. The Court dismissed the appeal, holding that the TDS compliance scheme treats each quarter as a separate compliance period with distinct due dates, and limitation must be computed quarterly, not annually. The order for the first three quarters passed on 15 March 2012 was held time-barred. The bench comprised Justices Gautam A. Ankhad and M.S. Karnik. The judgment was delivered by Justice Gautam A. Ankhad. Counsel appearing: A. K. Saxena (counsel for appellant), Jitendra Singh (counsel for respondent), Rajesh Gaikwad (counsel for respondent), Shivali Mhatre (counsel for respondent).

Summary

The CIT (TDS) appealed a Tribunal order holding that Section 201(1) proceedings against Vodafone for the first three quarters of AY 2009-10 were time-barred under Section 201(3) of the Income Tax Act. The Court dismissed the appeal, holding that the TDS compliance scheme treats each quarter as a separate compliance period with distinct due dates, and limitation must be computed quarterly, not annually. The order for the first three quarters passed on 15 March 2012 was held time-barred.

What was the outcome of The Commissioner Of Income-Tax ... vs Vodafone Cellular Ltd,?

The CIT (TDS) appealed a Tribunal order holding that Section 201(1) proceedings against Vodafone for the first three quarters of AY 2009-10 were time-barred under Section 201(3) of the Income Tax Act....

Judgment

Read the full judgment on the official India Courts portal.

Read on Indian Kanoon

Source: Indian Kanoon (ik-42853881)