ACIT v. Clough Engineering Ltd.

Bj Services Company Middle East Limited, Mumbai vs. Deputy Commissioner of Income Tax, Dehradun

Bench: Yogesh Kumar U.S. & Shrimanish Agarwalita No. 53/Ddn/2024 (A.Y. 2016-17) Assistant Commissioner Of V B J Services Me Company Income Tax, 13-A, Subhash S. Limited, Unit No. 203, Navi Road, Dehradun, Uttarakhand Mumbai,Thane, Maharashtra Pan:Aaacb8529N Appellant Respondent B J Services Me Company Vs Deputy Commissioner Of Limited, Unit No. 203, Navi Income Tax, Circle-1, Mumbai, Thane, International Taxation Maharashtra Income-Tax Office, Subhash Pan:Aaacb8529N Road, Dehradun, Uttarakhand

…he case of B J Services Co. Middle East reported in [200] 29 SOT 312 (Delhi) has decided the issue in favour of the revenue. But this decision has been considered by the Special Bench of Delhi Tribunal in the case of ACIT vs Clough Engineering Ltd reported in 138 TTJ 385 (Delhi)(SB). We have gone through the decision of Special Bench and we find in that case, the issue was concerned with taxability under treaty provisions and particularly interpreting the expression ‘in connection with PE’. Whereas in the instant case before us, the assessee had admittedly offered the income under the domestic provisions and had…

Asstt. Commissioner of Income Tax, Aayakar Bhawan vs. Bj Services Me Company Limited, Maharashtra

Bench: Yogesh Kumar U.S. & Shrimanish Agarwalita No. 53/Ddn/2024 (A.Y. 2016-17) Assistant Commissioner Of V B J Services Me Company Income Tax, 13-A, Subhash S. Limited, Unit No. 203, Navi Road, Dehradun, Uttarakhand Mumbai,Thane, Maharashtra Pan:Aaacb8529N Appellant Respondent B J Services Me Company Vs Deputy Commissioner Of Limited, Unit No. 203, Navi Income Tax, Circle-1, Mumbai, Thane, International Taxation Maharashtra Income-Tax Office, Subhash Pan:Aaacb8529N Road, Dehradun, Uttarakhand

…he case of B J Services Co. Middle East reported in [200] 29 SOT 312 (Delhi) has decided the issue in favour of the revenue. But this decision has been considered by the Special Bench of Delhi Tribunal in the case of ACIT vs Clough Engineering Ltd reported in 138 TTJ 385 (Delhi)(SB). We have gone through the decision of Special Bench and we find in that case, the issue was concerned with taxability under treaty provisions and particularly interpreting the expression ‘in connection with PE’. Whereas in the instant case before us, the assessee had admittedly offered the income under the domestic provisions and had…

Asstt. Commissioner of Income Tax, Aayakar Bhawan vs. Bj Services Me Company Limited, Maharashtra

Bench: Yogesh Kumar U.S. & Shrimanish Agarwalita No. 53/Ddn/2024 (A.Y. 2016-17) Assistant Commissioner Of V B J Services Me Company Income Tax, 13-A, Subhash S. Limited, Unit No. 203, Navi Road, Dehradun, Uttarakhand Mumbai,Thane, Maharashtra Pan:Aaacb8529N Appellant Respondent B J Services Me Company Vs Deputy Commissioner Of Limited, Unit No. 203, Navi Income Tax, Circle-1, Mumbai, Thane, International Taxation Maharashtra Income-Tax Office, Subhash Pan:Aaacb8529N Road, Dehradun, Uttarakhand

…he case of B J Services Co. Middle East reported in [200] 29 SOT 312 (Delhi) has decided the issue in favour of the revenue. But this decision has been considered by the Special Bench of Delhi Tribunal in the case of ACIT vs Clough Engineering Ltd reported in 138 TTJ 385 (Delhi)(SB). We have gone through the decision of Special Bench and we find in that case, the issue was concerned with taxability under treaty provisions and particularly interpreting the expression ‘in connection with PE’. Whereas in the instant case before us, the assessee had admittedly offered the income under the domestic provisions and had…

Dy. Commissioner of Income Tax, Aayakar Bhawan vs. Expro Gulf Limited, Cyprus

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaldeputy Commissioner Of Vs Expro Gulf Limited Income Tax, 13-A, Subhash Aerc Makarioi/111284, Road, Dehradun, Fortuna Court Block B, 2 & 3 Uttarakhand Floor Limassol Larnaca, Cyprus,248001 Pan:Aaace5272B Appellant Respondent Assessee By Sh. Amit Arora, Ca & Sh. Vishal Mishra, Ca Revenue By Sh. Mohan Lal Joshi, Sr. Dr Date Of Hearing 14/11/2025 Date Of Pronouncement 19/11/2025 Order

…he case of B J Services Co. Middle East reported in [200] 29 SOT 312 (Delhi) has decided the issue in favour of the revenue. But this decision has been considered by the Special Bench of Delhi Tribunal in the case of ACIT vs Clough Engineering Ltd reported in 138 TTJ 385 (Delhi)(SB). We have gone through the decision of Special Bench and we find in that case, the issue was concerned with taxability under treaty provisions and particularly interpreting the expression ‘in connection with PE’. Whereas in the instant case before us, the assessee had admittedly offered the income under the domestic provisions and had…

DCIT, Circle- 2, Intl. Taxation, Dehradun vs. Schlumberger Asia Services Ltd., Dehradun

In the result, the appeal of the assessee for the Asst Year 2015-16 is partly allowed and that of the revenue is dismissed

Bench: Shri Saktijit Dey & Shri M. Balaganeshita No. 5223/Del/2018 (A. Y.: 2015-16) Schlumberger Asia Services Ltd, Vs. Dcit, 14Th Floor, Tower-C, Building Circle-2, No. 1, Dlf City, Phase-Ii, International Taxation, Gurgaon Dehradun (Appellant) (Respondent) Pan: Aadcs1107J

…he case of B J Services Co. Middle East reported in [200] 29 SOT 312 (Delhi) has decided the issue in favour of the revenue. But this decision has been considered by the Special Bench of Delhi Tribunal in the case of ACIT vs Clough Engineering Ltd reported in 138 TTJ 385 (Delhi)(SB). We have gone through the decision of Special Bench and we find in that case, the issue was concerned with taxability under treaty provisions and particularly interpreting the expression ‘in connection with PE’. Whereas in the instant case before us, the assessee had admittedly offered the income under the domestic provisions and had…

Schlumberger Asia Services Ltd., Dehradun vs. DCIT, Circle- 2, Intl. Taxation, Dehradun

In the result, the appeal of the assessee for the Asst Year 2015-16 is partly allowed and that of the revenue is dismissed

Bench: Shri Saktijit Dey & Shri M. Balaganeshita No. 5223/Del/2018 (A. Y.: 2015-16) Schlumberger Asia Services Ltd, Vs. Dcit, 14Th Floor, Tower-C, Building Circle-2, No. 1, Dlf City, Phase-Ii, International Taxation, Gurgaon Dehradun (Appellant) (Respondent) Pan: Aadcs1107J

…he case of B J Services Co. Middle East reported in [200] 29 SOT 312 (Delhi) has decided the issue in favour of the revenue. But this decision has been considered by the Special Bench of Delhi Tribunal in the case of ACIT vs Clough Engineering Ltd reported in 138 TTJ 385 (Delhi)(SB). We have gone through the decision of Special Bench and we find in that case, the issue was concerned with taxability under treaty provisions and particularly interpreting the expression ‘in connection with PE’. Whereas in the instant case before us, the assessee had admittedly offered the income under the domestic provisions and had…

DCIT, Circle- 2, Intl. Taxation, Dehradun vs. Schlumberger Asia Services Ltd., Dehradun

In the result, the appeal of the assessee for the Asst Year 2015-16 is partly allowed and that of the revenue is dismissed

Bench: Shri Saktijit Dey & Shri M. Balaganeshita No. 5223/Del/2018 (A. Y.: 2015-16) Schlumberger Asia Services Ltd, Vs. Dcit, 14Th Floor, Tower-C, Building Circle-2, No. 1, Dlf City, Phase-Ii, International Taxation, Gurgaon Dehradun (Appellant) (Respondent) Pan: Aadcs1107J

…he case of B J Services Co. Middle East reported in [200] 29 SOT 312 (Delhi) has decided the issue in favour of the revenue. But this decision has been considered by the Special Bench of Delhi Tribunal in the case of ACIT vs Clough Engineering Ltd reported in 138 TTJ 385 (Delhi)(SB). We have gone through the decision of Special Bench and we find in that case, the issue was concerned with taxability under treaty provisions and particularly interpreting the expression ‘in connection with PE’. Whereas in the instant case before us, the assessee had admittedly offered the income under the domestic provisions and had…

Schlumberger Asia Services Ltd., Dehradun vs. DCIT, Circle- 2, Intl. Taxation, Dehradun

In the result, the appeal of the assessee for the Asst Year 2015-16 is partly allowed and that of the revenue is dismissed

Bench: Shri Saktijit Dey & Shri M. Balaganeshita No. 5223/Del/2018 (A. Y.: 2015-16) Schlumberger Asia Services Ltd, Vs. Dcit, 14Th Floor, Tower-C, Building Circle-2, No. 1, Dlf City, Phase-Ii, International Taxation, Gurgaon Dehradun (Appellant) (Respondent) Pan: Aadcs1107J

…he case of B J Services Co. Middle East reported in [200] 29 SOT 312 (Delhi) has decided the issue in favour of the revenue. But this decision has been considered by the Special Bench of Delhi Tribunal in the case of ACIT vs Clough Engineering Ltd reported in 138 TTJ 385 (Delhi)(SB). We have gone through the decision of Special Bench and we find in that case, the issue was concerned with taxability under treaty provisions and particularly interpreting the expression ‘in connection with PE’. Whereas in the instant case before us, the assessee had admittedly offered the income under the domestic provisions and had…