IN THE INCOME TAX APPELLATE TRIBUNAL “J” BENCH, MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER ITA No.671/AHD/2015 (Assessment Year: 2010-11)

Vodafone West Limited.

(formerly known as Vodafone Essar Gujarat Limited)

Vodafone House, B Wing, 4^th Floor, Corporate Road, ............... Appellant Prahladnagar, Ahmedabad- 380051 PAN : AAACF1190P v/s Deputy Commissioner of Income Tax Circle - 4(1)(2)

Ahmedabad ……………… Respondent ITA No.1634/AHD/2015 (Assessment Year: 2010-11)

Deputy Commissioner of Income Tax Circle 4(1)(2) ............... Appellant Ahmedabad v/s Vodafone West Limited (Formerly Known As Vodafone Essar Gujarat Limited)

Vodafone House, B Wing, 4^th Floor, Corporate Road, Prahladnagar, Ahmedabad- 380051 ……………… Respondent PAN : AAACF1190P P Assessee by : Shri K.K. Ved, Shri N.A. Patade Revenue by : Shri Pankaj Kumar, CIT-DR Date of Hearing – 06/11/2025 Date of Order - 11/12/2025

O R D E R

PER SANDEEP SINGH KARHAIL, J.M.

The present cross appeal arises from the final assessment order dated

23.02.2015, passed under section 143(3) read with section 144C of the Income Tax Act, 1961 ("the Act") pursuant to the directions dated 10.12.2014