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
…d from the services. With respect to the argument of the learned authorised representative that goods cannot be included for the purpose of Section 44 BB of the income tax act, it was submitted that the honourable Supreme Court in case of ONGC Ltd versus CIT 376 ITR 306 has held that the Pith & substance of each of the contract and agreement is required to be seen and if it is inextricably connected with the prospecting and extraction and production of mineral oil same should be considered for the provisions of Section 44 BB of the income tax act. It was further stated that the dominant purpose for each of the ag…