How many judgments cite CIT v. Halliburton Offshore Services Inc.?

50 judgments on BharatTax cite CIT v. Halliburton Offshore Services Inc. (300 ITR 265), spanning 2016 to 2025.

Which sections of the Income Tax Act does CIT v. Halliburton Offshore Services Inc. come up under?

It is most often cited in judgments turning on Section 143(3), Section 144C(13), Section 145A, Section 194-I, Section 194J, Section 44BB.

CIT v. Halliburton Offshore Services Inc.

300 ITR 265High Court2008#2298 most cited

What is CIT v. Halliburton Offshore Services Inc. authority for?

For computing profits under the presumptive taxation scheme of section 44BB, gross revenue excludes service tax collected and deposited by the assessee but includes mobilization/demobilization fees for offshore services.

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2016 to 2025.

Also referred to as

CIT v. Halliburton Offshore Services Inc. · section 44BB · presumptive taxation · gross revenue · service tax · mobilization fees · demobilization fees · includibility · offshore services · 300 ITR 265

Also reported as

169 Taxmann 138

Sections most often in play

Section 143(3)Section 144C(13)Section 145A Section 194-I Section 194J Section 44BB

Issues it is cited on

section 44da section 255(4)section 44d section 44bb section 44b section 3(b)section 115a section 9(1)(i)section 9(1)(vii)fees for technical services section 9(1)section 90

Judgments citing CIT v. Halliburton Offshore Services Inc.

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)

…ssue of taxability on reimbursement of expenses. The ld. AR has conceded that this issue is covered against the assessee and in favour of the Revenue by the decision of Hon’ble Uttarakhand High Court in the case of CIT vs. Halliburton Offshore Services Inc., 300 ITR 265. The Hon’ble Court has held as under on this issue : 5. Sec. 44BB provides that the deemed profits and gains under sub-s. (1) shall be @ 10 per cent of the aggregate amount specified in sub-s. (2). 25 ITA No.3889/Del./2010, 421 & 4831/Del./2012 We proceed to analyze sub-s. (2). Clause (a) of sub-s. (2) refers to the amounts, (A) paid to the as…

DDIT, Dehradun vs. M/S. Pride Offshore International Llc, New Delhi

ITA 2225/DEL/2014[2009-10]Status: DisposedITAT Delhi29 Jul 2016AY 2009-10

Bench: Shri J.S. Reddy & Shri Kuldip Singh

For Appellant: Shri Vidur Puri, CAFor Respondent: Shri Anuj Arora, CIT DR

Section 44B

…ating the need for accounting for individual receipts and payments etc. 3.2 Whether the Hon'ble DRP has erred in not applying/extending the ratio of the judgment of the Hon'ble Uttarakhand High Court in the case of CIT Vs. Halliburton Offshore Services Ins. (300 ITR 265) to the receipts on account of "equipment lost in hole" and "Communication Immersat Charges." 4. The appellant, Addl. Director of Income-tax, International Taxation, Dehradun (hereinafter referred to as ‘the revenue’), by filing the aforesaid appeal being ITA No.225/Del/2014, sought to set aside the impugned order dated 27.12.2013 passed by Dis…

DDIT, Dehradun vs. M/S. Pride Foramer Sas, New Delhi

ITA 1634/DEL/2014[2009-10]Status: DisposedITAT Delhi29 Jul 2016AY 2009-10

Bench: Shri J.S. Reddy & Shri Kuldip Singh

For Appellant: Shri Vidur Puri, CAFor Respondent: Shri Anuj Arora, CIT DR

Section 44B

M/S. Pride Foramer Sas, New Delhi vs. Addl. DIT, Dehradun

ITA 1405/DEL/2014[2009-10]Status: DisposedITAT Delhi29 Jul 2016AY 2009-10

Bench: Shri J.S. Reddy & Shri Kuldip Singh

For Appellant: Shri Vidur Puri, CAFor Respondent: Shri Anuj Arora, CIT DR

Section 44B

DCIT, Dehradun vs. M/S. Halliburton Offshore Services Inc., Mumbai

In the result, the appeal of the Revenue and the cross-objection of the assessee both are dismissed

ITA 6585/DEL/2014[2011-12]Status: DisposedITAT Delhi08 Jul 2016AY 2011-12

Bench: Shri G.D. Agrawalbefore Shri G.D. Agrawal & And Before Shri Before Shri G.D. Agrawalg.D. Agrawal & And Smt. Beena A. Pillai Smt. Beena A. Pillaismt. Beena A. Pillai Smt. Beena A. Pillai

Section 44BSection 44DSection 9(1)(vi)

…At the time of hearing before us, it was fairly conceded by the learned counsel that this issue is covered against the assessee by the decision of Hon'ble Jurisdictional High Court in the case of CIT and Another Vs. Halliburton Offshore Services Inc. – [2008] 300 ITR 265 (Uttarakhand). In the above mentioned case, the assessee rendered services to the ONGC. For the assessment year 1991-92, it claimed that the amount of Rs.6,16,989 received on account of reimbursement of freight and transportation charges actually incurred in respect of equipment was not includible while computing its income under section 44BB. Th…

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

…the decision of Hon’ble Delhi High Court in assessee’s own case in 300 ITR 265. 19. Ld DR supported the order of the lower authorities. 20. We have carefully considered the rival contentions and we are of the view that this is covered against the assessee in 300 ITR 265 wherein it has been held as under:- “5. Section 44BB provides that the deemed profits and gains under sub-section (1) shall be at the rate of 10 per cent of the aggregate amount specified in sub-section (2). We proceed to analyze sub-section (2). Clause (a) of sub-section (2) refers to the amounts, (A) paid to the assessee (whether in or out of I…

Helix Energy Solutions Group Inc, New Delhi vs. Addl DIT (It) RG 3, Mumbai

In the result, both the appeals filed by the assessee are allowed

ITA 1236/MUM/2013[2009-10]Status: DisposedITAT Mumbai29 Jun 2016AY 2009-10

Bench: Shri B.R.Baskaran & Shri Pawan Singh

For Appellant: Shri Neeraj Agarwala (AR)For Respondent: Shri Jasbir Chauhan (CIT)

Section 44B

…e i.e. favour of the Assessee and against the Revenue." 5. We have also considered the oral as well as written submission filed by the DR of the revenue. Ld DR for Revenue heavily relied upon a case of CIT vs. Halliburton Offshore Services Inc. reported vide 300 ITR 265/ (2008) taxman138(Ukd) (supra). With utmost regards to the decision of Uttrakhand High Court in Halliburton Offshore Services Inc, the issue before High Court was related with the reimbursement of freight and transportation charges, which is entirely different from the claim(s) involved in the present case. Thus the ratio decided by honourable Hi…

R&B Falcon (A) Pty Ltd., New Delhi vs. Addl. DIT, Dehradun

In the result the solitary ground of the appeal is dismissed

ITA 1215/DEL/2014[2010-11]Status: DisposedITAT Delhi03 Jun 2016AY 2010-11

Bench: Shri H S Sidhu & Shri Prashant Maharishi

For Appellant: CA. Amit ArroraFor Respondent: Mr. Anuj Arrora CIT DR

Section 143(3)Section 44Section 44B

…decision in IT No. 505/DES/2013 dated 16 August 2013. He referred to para No. 4 of that judgment wherein the coordinate bench relying on the decision is of Hon’ble jurisdictional High Court of Uttarakhand in case of Haliburton offshore services incorporation [300 ITR 265] has held that it all receipts which are intricately linked the services rendered by the assessee is to be considered as a part of the receipt for the purposes of computation of income useless as 44BB of the income tax act. 4. Learned DR also agreed with the above proposition and submitted that this issue is squarely covered against the assessee…

ADIT, Dehradun vs. M/S. R & B Falcon (A) Pty Ltd., Mumbai

In the result, the appeal of the Department is partly allowed

ITA 1048/DEL/2014[2010-11]Status: DisposedITAT Delhi29 Apr 2016AY 2010-11

Bench: Shri N.K. Saini & Shri Sudhanshu Srivastavaay: 2010-11 Adit Vs R & B Falcon (A) Pty Ltd., International Taxation, 1St Floor, Spectra High Street, Aayakar Bhawan, Hiranandani Business Park, 13A-Subhash Road, Powai, Mumbai. Dehraun. (Pan: Aaccr5345Q) (Appellant) (Respondent) Appellant By: Shri Anuj Arora, Cit Dr Respondent By: Shri Amit Arora, Ca Date Of Hearing: 08.02.2016 Date Of Pronouncement: 29.04.2016

For Appellant: Shri Anuj Arora, CIT DRFor Respondent: Shri Amit Arora, CA

Section 234BSection 44B

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘F’ NEW DELHI BEFORE SHRI N.K. SAINI, ACCOUNTANT MEMBER AND SHRI SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AY: 2010-11 ADIT vs R & B Falcon (A) Pty Ltd., International Taxation, 1st Floor, Spectra High Street, Aayakar Bhawan, Hiranandani Business Park, 13A-Subhash Road, Powai, Mumbai. Dehraun. (PAN: AACCR5345Q) (Appellant) (Respondent) Appellant by: Shri Anuj Arora, CIT DR Respondent by: Shri Amit Arora, CA Date of hearing: 08.02.2016 Date of pronouncement: 29.04.2016 ORDER PER SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER The present appeal has been preferred by t…

DDIT, New Delhi vs. M/S Scorpion Courageous Ltd., New Delhi

In the result, the Cross Objection of the assessee is partly allowed

ITA 4619/DEL/2012[2008-09]Status: DisposedITAT Delhi25 Apr 2016AY 2008-09

Section 143(2)Section 234BSection 44BSection 44DSection 9

…ed that the issue in question is squarely covered against the assessee by the judgements of the Uttarakhand High Court in the cases of (a) Sedco Forex International Inc. reported in 299 ITR 238; (b) in the case of Halliburton Offshore Service Inc. reported in 300 ITR 265 and (c) in the case of Trans Ocean Offshore Inc. 299 ITR 248. He further relied upon the order of the Assessing Officer as well as the findings of the D.R.P. He submitted that : “The issue of taxability of these amounts is settled by a number of the decisions of the Hon'ble Uttarakhand High Court. Some of these decisions are: Sedco Forex Interna…