YES BANK LTD.,MUMBAI vs. ADDL. CIT (TDS), DEHRADUN

In the result, the appeals of the assessee are allowed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usita No. 7498/Del/2017 : Asstt. Year : 2013-14 Ita No. 7499/Del/2017 : Asstt. Year : 2014-15

TDS AO passed an order dated 29 August 2016 under section 271C levying penalty of Rs.1,86,539 being 100% of the alleged non-deduction of tax at source including interest under section 201(1 A) of the Act. It was submitted by the assessee that, 1) UEPPCB is a statutory organisation constituted under the section 4 of Water (Prevention

YES BANK LTD.,MUMBAI vs. ADDL. CIT (TDS), DEHRADUN

In the result, the appeals of the assessee are allowed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usita No. 7498/Del/2017 : Asstt. Year : 2013-14 Ita No. 7499/Del/2017 : Asstt. Year : 2014-15

TDS AO passed an order dated 29 August 2016 under section 271C levying penalty of Rs.1,86,539 being 100% of the alleged non-deduction of tax at source including interest under section 201(1 A) of the Act. It was submitted by the assessee that, 1) UEPPCB is a statutory organisation constituted under the section 4 of Water (Prevention

DCIT (INTERNATIONAL TAXATION),CIRCLE-2, DEHRADUN vs. TRANSOCEAN OFFSHORE INTERNATIONAL VENTURE LTD., NOIDA

In the result, appeal of the revenue is dismissed

Bench: Shri Amit Shukladr. B.R.R. Kumar

46, E.C. Road, Dehradun (APPELLANT) (RESPONDENT) (PAN : AABCT6720C) Revenue by : Sh. T.S.Mapwal, Sr. DR Assessee by : Sh. Amit Arora, Adv. Date of Hearing: 09.11.2021 Date of Pronouncement: 25 .11.2021 2 ITA No.6174, 6175.Del.2017 Transocean Offshore O R D E R PER B.R.R.KUMAR, ACCOUNTANT MEMBER : Both appeals have been filed by the revenue against the order

DCIT, CIRCLE- 1, INTERNATIONAL TAXATION, DEHRADUN vs. TRANSOCEAN OFFSHORE DEEPWATER DRILLING INC, DEHRADUN

In the result, appeal of the revenue is dismissed

Bench: Shri Amit Shukladr. B.R.R. Kumar

46, E.C. Road, Dehradun (APPELLANT) (RESPONDENT) (PAN : AABCT6720C) Revenue by : Sh. T.S.Mapwal, Sr. DR Assessee by : Sh. Amit Arora, Adv. Date of Hearing: 09.11.2021 Date of Pronouncement: 25 .11.2021 2 ITA No.6174, 6175.Del.2017 Transocean Offshore O R D E R PER B.R.R.KUMAR, ACCOUNTANT MEMBER : Both appeals have been filed by the revenue against the order

DY. COMMISSIONER OF INCOME TAX, DEHRADUN vs. HALLIBURTON WORLDWIDE GMBH, DEHRADUN

In the result, the appeal is dismissed

Bench: Shri Yogesh Kumar Us & Shri Sanjay Awasthiआ.अ.सं/.I.T.A No.250/Ddn/2025 िनधा"रणवष"/Assessment Year:2016-17 बनाम Dy. Commissioner Of Income Tax, Halliburton Worldwide Gmbh 1St Floor, Ida, 46, E.C. Road, Aayakar Bhawan, 13-A, Subhash Road, Vs. Dehradun, Uttarakhand. Dehradun- 248001,Uttarakhand. Pan No.Aadch1061Q अपीलाथ" Appellant ""यथ"/Respondent

46, E.C. Road, Aayakar Bhawan, 13-A, Subhash Road, Vs. Dehradun, Uttarakhand. Dehradun- 248001,Uttarakhand. PAN No.AADCH1061Q अपीलाथ" Appellant ""यथ"/Respondent Assessee by Shri Amit Arora, CA &Shri Vishal Mishra, CA Revenue by Shri Mohan Lal Joshi, Sr. DR सुनवाईक"तारीख/ Date of hearing: 11.02.2026 18.02.2026 उ"ोषणाक"तारीख/Pronouncement on आदेश /O R D E R PERSANJAY AWASTHI, ACCOUNTANT

DCIT, CIRCLE- I, INTL. TAXATION, DEHRADUN vs. DEEPWATER PACIFIC 1 INC., DEHRADUN

In the result, appeal of the revenue is dismissed

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar

46, E.C. Road, (International Taxation), Circle-I, Dehradun Dehradun (APPELLANT) (RESPONDENT) (PAN : AADCD1582A) Revenue by : Sh. N.S.Jangpangi, CIT-DR Assessee by : Sh. Amit Arora, Adv. Date of Hearing: 09.11.2021 Date of Pronouncement: 25 .11.2021 O R D E R PER B.R.R.KUMAR, ACCOUNTANT MEMBER : This appeal has been filed by the revenue against the order

SCHLUMBERGER ASIA SERVICES LTD.,GURGAON vs. DDIT, DEHRADUN

In the result, the appeal filed by the Revenue is dismissed and the appeal filed by the assessee is partly allowed

Bench: Shri R.K. Panda & Shri C.N. Prasad[Assessment Year: 2011-12] Schlumberger Asia Services Deputy Director Of Income Tax Limited, (International Taxation), 14Th Floor, Tower C, Building Dehradun No.1, Dlf City, Phase Ii, Gurgaon-122002 Pan-Aadcs1107J Assessee Revenue [Assessment Year: 2011-12] Deputy Director Of Income Tax Schlumberger Asia Services (International Taxation), Limited, Dehradun 14Th Floor, Tower C, Building No.1, Dlf City, Phase Ii, Gurgaon-122002 Pan- Aadcs1107J Revenue Assessee Assessee By Sh. Salil Kapoor, Adv. Ms. Ananya Kappor & Ms. Soumya Singh, Adv. Revenue By Sh. T.S.Mapwal, Sr.Dr

TDS has not been given. The Id. AO must do so at the time of giving effect to this order. 10. Ground no. 9 challenges the levy of interest u/s 234B of the Act. This ground is allowed following the case of Maersk reported in 334 ITR 79 (UK). 11. Ground nos. 10 and 11 challenge the initiation of penalty

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

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

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

46. We have already decided this issue in the appeal of the assessee for assessment year 2006 – 07 wherein we have held that taxability of revenue from offshore supply of imported material is also chargeable to tax u/s 44 BB of the income tax act and dismissed those grounds. For the same reasons we dismiss ground number

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

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

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

46. We have already decided this issue in the appeal of the assessee for assessment year 2006 – 07 wherein we have held that taxability of revenue from offshore supply of imported material is also chargeable to tax u/s 44 BB of the income tax act and dismissed those grounds. For the same reasons we dismiss ground number

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

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

46. We have already decided this issue in the appeal of the assessee for assessment year 2006 – 07 wherein we have held that taxability of revenue from offshore supply of imported material is also chargeable to tax u/s 44 BB of the income tax act and dismissed those grounds. For the same reasons we dismiss ground number

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

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

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

46. We have already decided this issue in the appeal of the assessee for assessment year 2006 – 07 wherein we have held that taxability of revenue from offshore supply of imported material is also chargeable to tax u/s 44 BB of the income tax act and dismissed those grounds. For the same reasons we dismiss ground number

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

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

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

46. We have already decided this issue in the appeal of the assessee for assessment year 2006 – 07 wherein we have held that taxability of revenue from offshore supply of imported material is also chargeable to tax u/s 44 BB of the income tax act and dismissed those grounds. For the same reasons we dismiss ground number

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

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

46. We have already decided this issue in the appeal of the assessee for assessment year 2006 – 07 wherein we have held that taxability of revenue from offshore supply of imported material is also chargeable to tax u/s 44 BB of the income tax act and dismissed those grounds. For the same reasons we dismiss ground number

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

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

46. We have already decided this issue in the appeal of the assessee for assessment year 2006 – 07 wherein we have held that taxability of revenue from offshore supply of imported material is also chargeable to tax u/s 44 BB of the income tax act and dismissed those grounds. For the same reasons we dismiss ground number

BG EXPLORATION & PRODUCTION INDIA LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX DDIT/ADIT (INTERNATIONAL TAXATION ) CIRCLE-1, DEHRADUN

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

Bench: Shri R.K. Panda & Shri V.P. Raoassessment Years: 2016-17

46,607 being the difference of depreciation amount between the tax audit report and the computation. 10.2 The learned AO / DRP erred in not appreciating that this difference is on account ofdepreciation claimed on Global IT & T expenditure and that depreciation claim on GlobalIT & T expenditure was allowable as held by the Hon’ble ITAT in Appellant’s own case

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

In the result, appeal of the assessee in ITA No

46,384l- against Rs. 60,51,32,172/- revenue recognized by assessee. 7. In the course of hearing the assessee has filed following reconciliation of revenue on the basis of percentage completion method: 8. Ld. Counsel submitted that in A.Y. 2007-08 the revenue was recognized on percentage completion method by assessee and the same was accepted by AO. Similarly

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

In the result, appeal of the assessee in ITA No

46,384l- against Rs. 60,51,32,172/- revenue recognized by assessee. 7. In the course of hearing the assessee has filed following reconciliation of revenue on the basis of percentage completion method: 8. Ld. Counsel submitted that in A.Y. 2007-08 the revenue was recognized on percentage completion method by assessee and the same was accepted by AO. Similarly