CHIEF EDUCATION OFFICER,DEHRADUN vs. CIT(A), DEHRADUN

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra(Through Video Conferencing)

TDS statement under Section 200A of he Act. Thus, the said sub-Section 200A(1)(c) of the Act was came to be inserted with effect from 01.06.2015. 14. Now the dispute is with regard to the assessment years 2012- 13

CIT(A), DEHRADUN vs. CHIEF EDUCATION OFFICER, DEHRADUN

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra(Through Video Conferencing)

TDS statement under Section 200A of he Act. Thus, the said sub-Section 200A(1)(c) of the Act was came to be inserted with effect from 01.06.2015. 14. Now the dispute is with regard to the assessment years 2012- 13

CHIEF EDUCATION OFFICER,DEHRADUN vs. CIT(A), DEHRADUN

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra(Through Video Conferencing)

TDS statement under Section 200A of he Act. Thus, the said sub-Section 200A(1)(c) of the Act was came to be inserted with effect from 01.06.2015. 14. Now the dispute is with regard to the assessment years 2012- 13

CHIEF EDUCATION OFFICER,DEHRADUN vs. CIT(A), DEHRADUN

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra(Through Video Conferencing)

TDS statement under Section 200A of he Act. Thus, the said sub-Section 200A(1)(c) of the Act was came to be inserted with effect from 01.06.2015. 14. Now the dispute is with regard to the assessment years 2012- 13

CHIEF EDUCATION OFFICER,DEHRADUN vs. CIT(A), DEHRADUN

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra(Through Video Conferencing)

TDS statement under Section 200A of he Act. Thus, the said sub-Section 200A(1)(c) of the Act was came to be inserted with effect from 01.06.2015. 14. Now the dispute is with regard to the assessment years 2012- 13

CHIEF EDUCATION OFFICER,DEHRADUN vs. CIT (A), DEHRADUN

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra(Through Video Conferencing)

TDS statement under Section 200A of he Act. Thus, the said sub-Section 200A(1)(c) of the Act was came to be inserted with effect from 01.06.2015. 14. Now the dispute is with regard to the assessment years 2012- 13

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

13 of DRP rules 2009 dated 23 January 2012 for AY 2008-09. Addition qua services in connection with exploration/prospecting /extraction of mineral oil to non-PSC partners 1. The Ld AO has erred on facts and in law in assessing receipts of Rs. 174,219,718/- from non-PSC partners on account of provision of mud- engineering services

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

13 of DRP rules 2009 dated 23 January 2012 for AY 2008-09. Addition qua services in connection with exploration/prospecting /extraction of mineral oil to non-PSC partners 1. The Ld AO has erred on facts and in law in assessing receipts of Rs. 174,219,718/- from non-PSC partners on account of provision of mud- engineering services

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

13 of DRP rules 2009 dated 23 January 2012 for AY 2008-09. Addition qua services in connection with exploration/prospecting /extraction of mineral oil to non-PSC partners 1. The Ld AO has erred on facts and in law in assessing receipts of Rs. 174,219,718/- from non-PSC partners on account of provision of mud- engineering services

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

13 of DRP rules 2009 dated 23 January 2012 for AY 2008-09. Addition qua services in connection with exploration/prospecting /extraction of mineral oil to non-PSC partners 1. The Ld AO has erred on facts and in law in assessing receipts of Rs. 174,219,718/- from non-PSC partners on account of provision of mud- engineering services

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

13 of DRP rules 2009 dated 23 January 2012 for AY 2008-09. Addition qua services in connection with exploration/prospecting /extraction of mineral oil to non-PSC partners 1. The Ld AO has erred on facts and in law in assessing receipts of Rs. 174,219,718/- from non-PSC partners on account of provision of mud- engineering services

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

13 of DRP rules 2009 dated 23 January 2012 for AY 2008-09. Addition qua services in connection with exploration/prospecting /extraction of mineral oil to non-PSC partners 1. The Ld AO has erred on facts and in law in assessing receipts of Rs. 174,219,718/- from non-PSC partners on account of provision of mud- engineering services

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

13 of DRP rules 2009 dated 23 January 2012 for AY 2008-09. Addition qua services in connection with exploration/prospecting /extraction of mineral oil to non-PSC partners 1. The Ld AO has erred on facts and in law in assessing receipts of Rs. 174,219,718/- from non-PSC partners on account of provision of mud- engineering services

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

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

c) of the Note viz. the CBDT Circular No. 473 dated 29 October 1986 cannot be applied to the facts of the instant case as the same was in the context of deposit in NRE and FCNR bank accounts and deposits in public limited companies: In this connection it is submitted, as was argued during the course of the hearing

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

c) of the Note viz. the CBDT Circular No. 473 dated 29 October 1986 cannot be applied to the facts of the instant case as the same was in the context of deposit in NRE and FCNR bank accounts and deposits in public limited companies: In this connection it is submitted, as was argued during the course of the hearing

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

c) of the Note viz. the CBDT Circular No. 473 dated 29 October 1986 cannot be applied to the facts of the instant case as the same was in the context of deposit in NRE and FCNR bank accounts and deposits in public limited companies: In this connection it is submitted, as was argued during the course of the hearing

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

c) of the Note viz. the CBDT Circular No. 473 dated 29 October 1986 cannot be applied to the facts of the instant case as the same was in the context of deposit in NRE and FCNR bank accounts and deposits in public limited companies: In this connection it is submitted, as was argued during the course of the hearing