आदेश / ORDER

Per B.M. Biyani, AM:

These are the two appeals filed by assessee for Financial Year 2009-10 relevant to Assessment-Year 2010-11. The first appeal being ITA No. 415/ Ind/2014 is directed against revision-order dated 27.03.2014 passed by CIT (TDS), Bhopal u/s 263 of the Income-tax Act, 1961 [“Act”] which in turn arises out of order dated 30.03.2012 passed by ITO (TDS)-II, Indore [“AO”] u/s 201(1)/(1A). The second appeal being ITA No. 265/ Ind/2018 is directed against appeal-order dated 01.02.2018 passed u/s 250 by CIT(Appeal)-II, Indore [“CIT(A)”] which in turn arises out of order dated 28.07.2014 passed by DCIT (TDS), Indore [“AO”] u/s 201(1)/(1A) pursuant to the aforesaid revision-order dated 27.03.2014 passed by CIT (TDS), Bhopal u/s 263.

2. The background facts leading to these appeals are summed up as under:

(i) ITA No. 415/Ind/2014 – The assessee-company is engaged in the business of providing telecom services through pre-paid and post-paid connections. In order to provide such services, the assessee allowed certain amounts to distributors/dealers of pre-paid vouchers. Further, the assessee also took services from Other Telecom Operators [“OTOs”] and paid ‘roa