w w w . L a w y e r S e r v i c e s . i n



Verizon Data Services India Private Limited, Rep. by its Director, S. Ramakrishnan, Chennai v/s The Authority for Advance Rulings, New Delhi & Others


Company & Directors' Information:- I SERVICES INDIA PRIVATE LIMITED [Active] CIN = U72900DL2003PTC118851

Company & Directors' Information:- VERIZON DATA SERVICES INDIA PRIVATE LIMITED [Active] CIN = U72300TN2001PTC046551

Company & Directors' Information:- M G F SERVICES LIMITED [Amalgamated] CIN = U65910DL1987PLC029599

Company & Directors' Information:- R S SERVICES PRIVATE LIMITED [Active] CIN = U74900DL1989PTC038061

Company & Directors' Information:- S J SERVICES PRIVATE LIMITED [Active] CIN = U74140DL1988PTC034427

Company & Directors' Information:- AND DATA INDIA PRIVATE LIMITED [Active] CIN = U72200PN1998PTC016655

Company & Directors' Information:- AND DATA INDIA PRIVATE LIMITED [Strike Off] CIN = U99999MH1998PTC117230

Company & Directors' Information:- VERIZON INDIA PRIVATE LIMITED [Active] CIN = U74899DL2000PTC103136

Company & Directors' Information:- AMP E - SERVICES PRIVATE LIMITED [Active] CIN = U51909MN2013PTC008361

Company & Directors' Information:- L M J SERVICES LTD [Active] CIN = L93000WB1983PLC035807

Company & Directors' Information:- G K SERVICES PRIVATE LIMITED [Active] CIN = U65990MH1994PTC078529

Company & Directors' Information:- E I C SERVICES PRIVATE LIMITED [Strike Off] CIN = U74899DL1985PTC022426

Company & Directors' Information:- H S SERVICES PRIVATE LIMITED [Active] CIN = U74900KA2014PTC074321

Company & Directors' Information:- G V INDIA SERVICES PRIVATE LIMITED [Active] CIN = U74900DL2010PTC212026

Company & Directors' Information:- ADVANCE SERVICES PRIVATE LIMITED [Active] CIN = U74910DL1999PTC098489

Company & Directors' Information:- A TO Z SERVICES PRIVATE LIMITED [Active] CIN = U74999MH2007PTC168484

Company & Directors' Information:- O P T SERVICES INDIA PRIVATE LIMITED [Active] CIN = U63013DL1996PTC083397

Company & Directors' Information:- S P DATA PVT LTD [Strike Off] CIN = U72502WB1989PTC047578

Company & Directors' Information:- G & G SERVICES PRIVATE LIMITED [Active] CIN = U45201DL2012PTC230905

Company & Directors' Information:- ADVANCE E SERVICES PRIVATE LIMITED [Active] CIN = U74899DL2005PTC140212

Company & Directors' Information:- A N Y SERVICES PRIVATE LIMITED [Active] CIN = U74899DL1995PTC071457

Company & Directors' Information:- P C SERVICES PRIVATE LIMITED [Strike Off] CIN = U00894KA1985PTC006606

Company & Directors' Information:- M. V. S SERVICES INDIA PRIVATE LIMITED [Active] CIN = U93000DL2013PTC252172

Company & Directors' Information:- S D SERVICES PVT LTD [Active] CIN = U51109AS1998PTC005293

Company & Directors' Information:- C & R SERVICES (INDIA) PRIVATE LIMITED [Active] CIN = U74140KA1996PTC019645

Company & Directors' Information:- A. H. SERVICES PRIVATE LIMITED [Active] CIN = U74990MH2009PTC193917

Company & Directors' Information:- M E R I T SERVICES PRIVATE LIMITED [Strike Off] CIN = U51900MH1999PTC118445

Company & Directors' Information:- P F P SERVICES PRIVATE LIMITED [Active] CIN = U74900WB2009PTC139742

Company & Directors' Information:- M K N DATA SERVICES PRIVATE LIMITED [Active] CIN = U74140DL2013PTC257885

Company & Directors' Information:- J. S. P. SERVICES PRIVATE LIMITED [Active] CIN = U63040DL1996PTC075731

Company & Directors' Information:- INDIA SERVICES LIMITED [Liquidated] CIN = U99999TN1946PLC000976

Company & Directors' Information:- U M S SERVICES LIMITED [Active] CIN = U03210TZ1982PLC001208

Company & Directors' Information:- G I SERVICES INDIA LIMITED [Active] CIN = U74140DL2008PLC184088

Company & Directors' Information:- E AND E SERVICES LIMITED [Strike Off] CIN = U65992KL1988PLC005094

Company & Directors' Information:- S R V N SERVICES PRIVATE LIMITED [Strike Off] CIN = U50200DL2004PTC124035

Company & Directors' Information:- A R SERVICES PRIVATE LIMITED [Active] CIN = U00000DL2001PTC109578

Company & Directors' Information:- J AND J SERVICES PRIVATE LIMITED [Active] CIN = U51900MH1995PTC092554

Company & Directors' Information:- L B D SERVICES PRIVATE LIMITED [Active] CIN = U00359BR1991PTC004694

Company & Directors' Information:- P RAMAKRISHNAN & COMPANY PRIVATE LIMITED [Active] CIN = U74999TN2013PTC091075

Company & Directors' Information:- M P SERVICES INDIA PRIVATE LIMITED [Strike Off] CIN = U74999PN1999PTC013531

Company & Directors' Information:- B I N A R Y SERVICES (INDIA) PRIVATE LIMITED [Strike Off] CIN = U72900DL2000PTC103072

Company & Directors' Information:- D & D SERVICES INDIA PRIVATE LIMITED [Strike Off] CIN = U51909DL1998PTC093967

Company & Directors' Information:- DATA SERVICES PRIVATE LIMITED [Strike Off] CIN = U74210TN1970PTC005878

Company & Directors' Information:- S C L SERVICES PRIVATE LIMITED [Active] CIN = U63012TN2001PTC046650

Company & Directors' Information:- A B SERVICES PRIVATE LIMITED [Strike Off] CIN = U74140DL1998PTC093545

Company & Directors' Information:- G P SERVICES PRIVATE LIMITED [Strike Off] CIN = U74899DL1989PTC037683

Company & Directors' Information:- A. S. V. P. SERVICES PRIVATE LIMITED [Strike Off] CIN = U74999HR2014PTC052304

Company & Directors' Information:- R AND T SERVICES PRIVATE LTD. [Strike Off] CIN = U72501DL1998PTC096640

Company & Directors' Information:- S S SERVICES PVT LTD [Strike Off] CIN = U74140WB1988PTC044009

Company & Directors' Information:- S S D SERVICES PRIVATE LIMITED [Active] CIN = U74910RJ1996PTC012694

Company & Directors' Information:- V & V SERVICES PRIVATE LIMITED [Strike Off] CIN = U74990MH2010PTC206211

Company & Directors' Information:- D S SERVICES PRIVATE LIMITED [Strike Off] CIN = U65923MH2012PTC226482

Company & Directors' Information:- P AND I SERVICES PRIVATE LIMITED [Active] CIN = U63090MH1981PTC024997

Company & Directors' Information:- F F C SERVICES PRIVATE LIMITED [Active] CIN = U74900PN2014PTC153348

Company & Directors' Information:- R. B. SERVICES PRIVATE LIMITED [Active] CIN = U74999MH2017PTC302692

Company & Directors' Information:- Q C SERVICES PRIVATE LIMITED [Active] CIN = U74999PN2013PTC148110

Company & Directors' Information:- S. R. DATA SERVICES PRIVATE LIMITED [Active] CIN = U72200WB1998PTC092777

Company & Directors' Information:- S N SERVICES PRIVATE LIMITED [Strike Off] CIN = U74900JK2014PTC004110

Company & Directors' Information:- R N SERVICES PRIVATE LIMITED [Strike Off] CIN = U74900CH2013PTC034757

Company & Directors' Information:- R M E-SERVICES PRIVATE LIMITED [Active] CIN = U72300DL2007PTC166470

Company & Directors' Information:- NEW DELHI E SERVICES PRIVATE LIMITED [Active] CIN = U72900DL2007PTC165097

Company & Directors' Information:- A Y SERVICES PRIVATE LIMITED [Active] CIN = U74140DL2012PTC239759

Company & Directors' Information:- DELHI SERVICES PRIVATE LIMITED [Strike Off] CIN = U74999DL1950PTC001721

Company & Directors' Information:- V. S. SERVICES PRIVATE LIMITED [Strike Off] CIN = U74999DL2012PTC233958

Company & Directors' Information:- A R J SERVICES PRIVATE LIMITED [Active] CIN = U72200DL2015PTC286948

Company & Directors' Information:- M K R SERVICES PRIVATE LIMITED [Strike Off] CIN = U93000DL2012PTC242159

Company & Directors' Information:- G W SERVICES PVT LTD [Strike Off] CIN = U79140DL2001PTC111194

Company & Directors' Information:- B 2 B SERVICES PRIVATE LIMITED [Strike Off] CIN = U74140HR2013PTC049213

Company & Directors' Information:- R K SERVICES PRIVATE LIMITED [Active] CIN = U45200HR2007PTC041783

Company & Directors' Information:- A. R. T. SERVICES PRIVATE LIMITED [Active] CIN = U51900GJ2009PTC056248

Company & Directors' Information:- B 9 N SERVICES PRIVATE LIMITED [Active] CIN = U74900KL2012PTC032087

Company & Directors' Information:- 7-A SERVICES PRIVATE LIMITED [Active] CIN = U74999DL2019PTC359011

Company & Directors' Information:- C R D SERVICES PVT LTD [Active] CIN = U72300AS1988PTC003097

Company & Directors' Information:- B I M SERVICES PRIVATE LIMITED [Strike Off] CIN = U74140KA1974PTC002694

Company & Directors' Information:- T Q M SERVICES PVT. LTD. [Strike Off] CIN = U74140DL1999PTC101341

Company & Directors' Information:- ADVANCE LIMITED [Not available for efiling] CIN = U99999MH1934PTC002117

    W.P. Nos. 23045 to 23047 of 2011 & M.P. Nos. 1, 1 & 1 of 2011

    Decided On, 31 January 2020

    At, High Court of Judicature at Madras

    By, THE HONOURABLE MR. JUSTICE C. SARAVANAN

    For the Petitioner: N. Venkatraman, Senior Counsel for N. Muthukumar, Advocate. For the Respondents: M/s. Hema Muralikrishnan, Standing Counsel.



Judgment Text


(Prayer in W.P.No.23045/2011: Writ Petition filed under Article 226 of the Constitution of India praying to issue a Writ of Certiorari calling for the records in F.No.ITO(IT)(1)(2)/AAR/11-12 dated 27.09.2011 relating to the Assessment Year 2009-10 on the file of the 2nd respondent, quash the same.

In W.P.No.23046/2011: Writ Petition filed under Article 226 of the Constitution of India praying to issue a Writ of Certiorari calling for the records in F.No.ITO(IT)(1)(2)/AAR/11-12 dated 27.09.2011 relating to the Assessment Year 2010-11 on the file of the 2nd respondent, quash the same.

In W.P.No.23047/2011: Writ Petition filed under Article 226 of the Constitution of India praying to issue a Writ of Certiorari calling for the records in F.No.ITO(IT)(1)(2)/AAR/11-12 dated 27.09.2011 relating to the Assessment Year 2011-12 on the file of the 2nd respondent, quash the same.)

Common Order:

1. These Writ Petitions have been filed praying to issue a Writ of Certiorari calling for the records in F.No.ITO(IT)(1)(2)/AAR/11-12 dated 27.09.2011 relating to the Assessment Years 2009-10; 2010- 11 and 2011-12 respectively on the file of the 2nd respondent and quash the same.

2. The impugned notices have been issued pending disposal of both the petitioner's and the respondents revenue's Special Leave Petitions before the Hon'ble Supreme Court.

3. The respective Special Leave Petitions have been filed before the Hon'ble Supreme Court against the order dated 09.08.2011 of the Division Bench of this Court in W.P.No.14921 of 2011. The said Writ Petition was filed by the petitioner against the order dated 27.05.2011 of the Authority for Advance Rulings (Income Tax), New Delhi.

4. By the said order, the Division Bench of this Court has partly allowed the above said Writ Petition and partly remitted the case back to the Authority for Advance Rulings (Income Tax), New Delhi, to pass a fresh order. It is during the pendency of the aforesaid appeals, the impugned notices have been issued.

5. Technically the issue is pending before the Authority for Advance Rulings (Income Tax), New Delhi in view of the order of the Division Bench of this Court in W.P.No.14921 of 2011, but also is awaiting for further orders in the respective Special Leave Petitions of the respective parties herein.

6. As per Section 245RR of the Income Tax Act, 1961, no income tax authorities or the Appellate Authorities shall proceed to decide any issue in respect of which an application has been made by an applicant under Section 245Q(1) of the Income Tax Act, 1961.

7. Since the issue is pending before the Authority for Advance Rulings (Income Tax), the 2nd respondent cannot proceed further. Therefore, no useful purpose will be served in filing upon the petitioner to appear for a hearing in respect of an issue which is pending resolution before the Authority for Advance Rulings (Income Tax), New Delhi.

8. I am therefore inclined to direct the 2nd respondent to keep the hearing pursuant to the impugned notices in abeyanc

Please Login To View The Full Judgment!

e and to await for further outcome of decision of the Hon'ble Supreme Court. The 2nd respondent may call upon the petitioner for a hearing subject to the outcome of decision of the Hon'ble Supreme Court. 9. Accordingly, the present Writ Petitions stand disposed. No cost. Consequently, the connected Miscellaneous Petitions are closed.
O R