Baker Hughes Asia-Pacific Ltd. v. ACIT

151 ITD 79Income Tax Appellate Tribunal#11160 most cited
9

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2021.

Judgments citing Baker Hughes Asia-Pacific Ltd. v. ACIT

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 5584/DEL/2013[2010-11]Status: DisposedITAT Dehradun08 Jun 2021AY 2010-11

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

…profits to be attributed to permanent establishment in India based on profit attribution report. He submitted that the aforesaid view is supported by the decision of the coordinate bench of the tribunal in the case of Baker Hughes Asia-Pacific Ltd versus ACIT 151 ITD 79 (Delhi ) which is affirmed by the Uttaranchal High Court in ITA number 64 of 2014. 12. The learned departmental representative vehemently supported the orders of the lower authorities. He submitted that this appeal is arising out of the order passed by the learned Director Of International Taxation u/s 263 of the income tax act pursuant to which t…

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 5583/DEL/2013[2007-08]Status: DisposedITAT Dehradun08 Jun 2021AY 2007-08

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

…profits to be attributed to permanent establishment in India based on profit attribution report. He submitted that the aforesaid view is supported by the decision of the coordinate bench of the tribunal in the case of Baker Hughes Asia-Pacific Ltd versus ACIT 151 ITD 79 (Delhi ) which is affirmed by the Uttaranchal High Court in ITA number 64 of 2014. 12. The learned departmental representative vehemently supported the orders of the lower authorities. He submitted that this appeal is arising out of the order passed by the learned Director Of International Taxation u/s 263 of the income tax act pursuant to which t…

ADIT (INTERNATIONAL TAXATION), DEHRADUN vs. M/S. M.I, OVERSEAS LTD., MUMBAI

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 5565/DEL/2013[2010-11]Status: DisposedITAT Dehradun08 Jun 2021AY 2010-11

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

…profits to be attributed to permanent establishment in India based on profit attribution report. He submitted that the aforesaid view is supported by the decision of the coordinate bench of the tribunal in the case of Baker Hughes Asia-Pacific Ltd versus ACIT 151 ITD 79 (Delhi ) which is affirmed by the Uttaranchal High Court in ITA number 64 of 2014. 12. The learned departmental representative vehemently supported the orders of the lower authorities. He submitted that this appeal is arising out of the order passed by the learned Director Of International Taxation u/s 263 of the income tax act pursuant to which t…

ADIT (INTERNATIONAL TAXATION), DEHRADUN vs. M/S. M.I, OVERSEAS LTD., MUMBAI

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 5564/DEL/2013[2007-08]Status: DisposedITAT Dehradun08 Jun 2021AY 2007-08

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

…profits to be attributed to permanent establishment in India based on profit attribution report. He submitted that the aforesaid view is supported by the decision of the coordinate bench of the tribunal in the case of Baker Hughes Asia-Pacific Ltd versus ACIT 151 ITD 79 (Delhi ) which is affirmed by the Uttaranchal High Court in ITA number 64 of 2014. 12. The learned departmental representative vehemently supported the orders of the lower authorities. He submitted that this appeal is arising out of the order passed by the learned Director Of International Taxation u/s 263 of the income tax act pursuant to which t…

ADIT, DEHRADUN vs. M/S. M.I. OVERSEAS LTD., NOIDA

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 3045/DEL/2013[2006-07]Status: DisposedITAT Dehradun08 Jun 2021AY 2006-07

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

…profits to be attributed to permanent establishment in India based on profit attribution report. He submitted that the aforesaid view is supported by the decision of the coordinate bench of the tribunal in the case of Baker Hughes Asia-Pacific Ltd versus ACIT 151 ITD 79 (Delhi ) which is affirmed by the Uttaranchal High Court in ITA number 64 of 2014. 12. The learned departmental representative vehemently supported the orders of the lower authorities. He submitted that this appeal is arising out of the order passed by the learned Director Of International Taxation u/s 263 of the income tax act pursuant to which t…

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 2956/DEL/2013[2006-07]Status: DisposedITAT Dehradun08 Jun 2021AY 2006-07

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

…profits to be attributed to permanent establishment in India based on profit attribution report. He submitted that the aforesaid view is supported by the decision of the coordinate bench of the tribunal in the case of Baker Hughes Asia-Pacific Ltd versus ACIT 151 ITD 79 (Delhi ) which is affirmed by the Uttaranchal High Court in ITA number 64 of 2014. 12. The learned departmental representative vehemently supported the orders of the lower authorities. He submitted that this appeal is arising out of the order passed by the learned Director Of International Taxation u/s 263 of the income tax act pursuant to which t…

MI OVERSEAS LTD.,NEW DELHI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 3072/DEL/2012[2009-10]Status: DisposedITAT Dehradun08 Jun 2021AY 2009-10

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

…profits to be attributed to permanent establishment in India based on profit attribution report. He submitted that the aforesaid view is supported by the decision of the coordinate bench of the tribunal in the case of Baker Hughes Asia-Pacific Ltd versus ACIT 151 ITD 79 (Delhi ) which is affirmed by the Uttaranchal High Court in ITA number 64 of 2014. 12. The learned departmental representative vehemently supported the orders of the lower authorities. He submitted that this appeal is arising out of the order passed by the learned Director Of International Taxation u/s 263 of the income tax act pursuant to which t…

B J SERVICES CO. MIDDLE EAST LTD.,DEHRADUN vs. ADIT(INTL. TAXATION), DEHRADUN

In the result, all the three appeals of the assessee are partly allowed for

ITA 3889/DEL/2010[2007-08]Status: DisposedITAT Delhi09 Dec 2016AY 2007-08

Bench: : Shri Sunil Kumar Yadav & Shri L.P. Sahu

For Appellant: Sh. Amil Arora, C.AFor Respondent: Sh. Anuj Arora, CIT/DR
Section 143(3)Section 144CSection 234BSection 271BSection 44BSection 9(1)(vii)

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH ‘A’ NEW DELHI BEFORE : SHRI SUNIL KUMAR YADAV, JUDICIAL MEMBER & SHRI L.P. SAHU, ACCOUNTANT MEMBER ITA No. 3889/Del./2010, 421 & 4831/Del./2012 Asstt. Year : 2007-08, 2009-09 & 2009-10 B.J. Services Company Middle East Ltd., vs. ADIT (Intl. Taxation), C/o Neeraj Nagalia & Co. , 16, Astlye Hall, Dehradun. Dehradun (PAN: AAACB 8529N) (Appellant) (Respondent) Appellant by : Sh. Amil Arora, C.A. Respondent by : Sh. Anuj Arora, CIT/DR Date of hearing : 26.09.2016 Date of pronouncement : 09.12.2016 ORDER Per L.P. Sahu, Accountant Member: These three appeals…

ADIT, DEHRADUN vs. M/S. HALLIBURTON OFFSHORE SERVICES INC., DEHRADUN

ITA 1332/DEL/2012[2005-06]Status: DisposedITAT Delhi30 Jun 2016AY 2005-06

Bench: Shri I.C.Sudhir & Shri Prashant Maharishiadit, Halliburton Offshore Services International Taxation, Inc. , Vs. 13-A,Subhash Road, C/O. Nangia & Company, Ca, Aayakar Bhawan, 75/7, Rajpur Road, Dehradun Dehradun Pan:Aaach5154M (Appellant) (Respondent) Halliburton Offshore Services Addl. Cit, Inc. , International Taxation, Vs. C/O. Nangia & Company, Ca, Subhash Road, Suite-4A, Plaza M-6, Jasola, Dehradun New Delhi Pan:Aaach5154M (Appellant) (Respondent) Halliburton Offshore Services Inc. , Adit, C/O. Nangia & Company, Ca, International Taxation, Vs. Suite-4A, Plaza M-6, Jasola, 13-A,Subhash Road, New Delhi Aayakar Bhawan, Pan:Aaach5154M Dehradun (Appellant) (Respondent) Halliburton Offshore Services Inc. Vs Ddit (International Taxation)

Section 144CSection 44Section 44BSection 9

…ht of the applicable legal position. 7. Learned Commissioner (DR) has, even while accepting that the same issue came up for consideration before coordinate benches in the cases of Baker Hughes Asia Pacific Ltd. v. Addl. DIT (Int. Tax.) [2014] 47 taxmann.com 1/151 ITD 79 (Delhi) and Baker Hughes Asia Pacific Ltd. v. ADIT [ITA No. 6476/Del/12; order dated 5th September 2014] and this issue was decided in favour of the assessee, contended that "no case can be held to be covered, standing as it does on own facts which are distinguishable". She has elaborate arguments in support of Halliburton Offshore Services Inc. V…

Baker Hughes Asia-Pacific Ltd. v. ACIT (151 ITD 79) — Cited in 9 Judgments | BharatTax