In all these appeals, common questions arise for consideration. Hence, they are being considered simultaneously.

2. All the appeals are preferred by appellants – Revenue by raising the following substantial questions of law:

1. Whether, on the facts and in the circumstances of the case, the Tribunal is right in law in holding that the assessee could not have been deemed as one in default for non-deduction of tax at source on roaming charges paid by it to other service providers when the Assessing Authority has rightly held as assessee in default due to no deduction of TDS as required under Section 194H and 194J of the Income Tax Act, 1961 (for short, ‘the Act’)?

2. Whether, on the facts and in the circumstances of the case, the Tribunal is right in law in holding that the data link charges does not require any human intervention and that the charges received or paid on account of this is not technical fees and does not fall under purview of Section 194J of the Act even when the Assessing Authority rightly treated the payment made by Vodafone South Limited to various operators as technical services falling within the ambit of the provisions of Section 194J of the Act?

3. Whether