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

Permanent Establishment in the following cases: • Dehradun Bench of the Tribunal in the case of Baker Hughes Singapore Pte. Ltd. vs. ACIT [ITA No. 5337/DDN/2018] dated 08 February 2022 (copy enclosed); • Delhi Bench of the Tribunal in the case of Transocean Offshore International Ventures Ltd. v/s. DCIT [2022] 136 taxmann.com 351 (Delhi - Trib.) (copy enclosed).” ITA No. 6126/Del/2017

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

Permanent Establishment in the following cases: • Dehradun Bench of the Tribunal in the case of Baker Hughes Singapore Pte. Ltd. vs. ACIT [ITA No. 5337/DDN/2018] dated 08 February 2022 (copy enclosed); • Delhi Bench of the Tribunal in the case of Transocean Offshore International Ventures Ltd. v/s. DCIT [2022] 136 taxmann.com 351 (Delhi - Trib.) (copy enclosed).” ITA No. 6126/Del/2017

GULF PIPING COMPANY WLL,UNITED ARAB EMIRATES vs. DY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

permanent establishment (“PE”) in India and the activities were utilized for the purpose of making or earning income from a source outside India. Since the provisions under the India-UAE DTAA are more beneficial to the assessee, the same should be applied. He further submitted that the decision of the Chennai Tribunal in the case of TVS Electronics (supra) which

GULF PIPING COMPANY WLL,ABU DHABI vs. DY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

permanent establishment (“PE”) in India and the activities were utilized for the purpose of making or earning income from a source outside India. Since the provisions under the India-UAE DTAA are more beneficial to the assessee, the same should be applied. He further submitted that the decision of the Chennai Tribunal in the case of TVS Electronics (supra) which

GULF PIPING COMPANY WLL,UNITED ARAB EMIRATES vs. DY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

permanent establishment (“PE”) in India and the activities were utilized for the purpose of making or earning income from a source outside India. Since the provisions under the India-UAE DTAA are more beneficial to the assessee, the same should be applied. He further submitted that the decision of the Chennai Tribunal in the case of TVS Electronics (supra) which

SERCEL SA ,DEHRADUN vs. DCIT, CIRCLE-2, DDN, DEHRADUN

In the result, the appeal of the assessee is allowed

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

TDS was deducted by Oil and Natural Gas Corporation Limited (ONGS) u/s 195 of the Act, in it’s ITR. The assessee has reported an amount of Rs. 108,27,23,947/- as exempt in the Schedule EI: Exempt Income. In order to examine the veracity of the assessee’s claims, notices u/s 142(1) along with questionnaires were issued

SAMSUNG HEAVY INDUSTRIES CO. LTD.,GURGAON vs. DCIT (INTERNATIONAL TAXATION), DEHRADUN

In the result, appeal of the assessee in ITA No

Permanent Establishment (PE) and income computed at profit rate of 25% thereof. While doing so, the ld AO rejected the books of account and rejected book results shown by the assessee. In AY 2008-09, the Tribunal remanded the matter to the file of the ld AO with regard to determination of profit for outsource supply vide its order

DCIT (INTERNATIONAL TAXATION), DEHRADUN vs. M/S. SAMSUNG HEAVY INDUSTRIES CO. LTD., GURGAON

In the result, appeal of the assessee in ITA No

Permanent Establishment (PE) and income computed at profit rate of 25% thereof. While doing so, the ld AO rejected the books of account and rejected book results shown by the assessee. In AY 2008-09, the Tribunal remanded the matter to the file of the ld AO with regard to determination of profit for outsource supply vide its order