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

13 taxmann.com 113 submitted as a part of the case law compilation Vol I- please refer page Nos. 29 to 35 of the compilation) has held - that one can take the shelter of Circular No. 473 (supra), if the reliance on the same gives a logical and a righteous conclusion (relevant portion extracted): ITA No. 6126/Del/2017 & ITA No. 5223/Del/2018 (Assessee

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

13 taxmann.com 113 submitted as a part of the case law compilation Vol I- please refer page Nos. 29 to 35 of the compilation) has held - that one can take the shelter of Circular No. 473 (supra), if the reliance on the same gives a logical and a righteous conclusion (relevant portion extracted): ITA No. 6126/Del/2017 & ITA No. 5223/Del/2018 (Assessee

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

13 taxmann.com 113 submitted as a part of the case law compilation Vol I- please refer page Nos. 29 to 35 of the compilation) has held - that one can take the shelter of Circular No. 473 (supra), if the reliance on the same gives a logical and a righteous conclusion (relevant portion extracted): ITA No. 6126/Del/2017 & ITA No. 5223/Del/2018 (Assessee

DR. VIRENDRA SWAROOP EDUCATIONAL FOUNDATION,KANPUR vs. ACIT, CENTRAL CIRCLE, DEHRADUN, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2023-24] Dr. Virendra Swaroop Vs Acit Educational Foundation Central Circle 15/96, Civil Lines, Kanpur Dehradun Uttar Pradesh-208001 Pan-Aaajd0224D Appellant Respondent Assessee By Shri Salil Kapoor, Adv. Shri Rajiv Sahni, Ca Shri Sumit Lal Chandanim, Adv. Shri Shivam Yadav, Adv. & Ms. Ananya Kapoor, Adv. Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 11.12.2025 Date Of Pronouncement 16.01.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 16.09.2025 By Ld. Pr. Commissioner Of Income Tax (Central), Kanpur [“Pcit”] Passed U/S 12(Ab)(4)(Ii) Of The Income Tax Act, 1961[“The Act”] Cancelling The Registration Granted U/S 12A Of The Act From Assessment Year 2023-24 & Onwards.

TDS and the same is adjusted towards the payment for said purpose and the fact that other party had noted the same as unsecured loan in his books of accounts is immaterial. 12. That the PCIT, had erred on facts and in law, in holding that there is cash transaction and adjustment towards the payment of car, whereas, there

INSTITUTE OF CLINICAL RESEARCH INDIA SOCIETY,DEHRADUN vs. CIT(A), DEHRADUN

Appeal is allowed

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh(Through Video Conferencing) Assessment Year: 2012-13 Institute Of Clinical Research Vs. Commissioner Of Income India Society, Tax (Appeals), 1St Floor, Building No.1, Dehradun Treenetra Vihar, Near Kargt Chowk, Dehradun Pan :Aabai3710P (Appellant) (Respondent) Assessee By None Department By Sh. Amar Pal Singh, Sr. Dr

1) to Section 11(5). Section 13 provides exception to Section 11 wherein such an income can be excluded from the exempt income of the trust. Thus, Section 11 to 13 provides for application of income by a trust for charitable purposes and to that extent, subject to certain conditions, income of the trust is treated to be exempted from

MB PETROLEUM SERVICES LLC,MUMBAI vs. DDIT, DEHRADUN

In the result, the appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Saktijit Dey & Shri M. Balaganeshmb Petroleum Services Llc, Vs. Ddit, Kirtane & Pandit, H-16, Circle-1, Saraswati Colony, Sitaldevi International Taxation, Temple Road, Mahim, Dehradun Mumbai (Appellant) (Respondent) Pan: Aaecm2604H

D E R PER M. BALAGANESH, A. M.: 1. The appeal in ITA No. 1828/Del/2015 arises out of the order of the AO/ DCIT, International Taxation, Circle-1, Dehradun [hereinafter referred to as „ld. AO)‟, in short] in for A.Y. 2010-11 dated 30.01.2015 passed u/s 143(3)/144C(13) of the Income-tax Act, 1961 (hereinafter referred

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 filed by the assessee is partly allowed for statistical purposes

13) by the AO for the assessment year 2017-18. 2. Facts of the case, in brief, are that the assessee (BGEPIL) is a non-resident company incorporated in the Cayman Islands with limited liability and is engaged in the business of exploration & extraction of mineral oils consequent upon Production Sharing Contracts (PSC) signed with the Government of India

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

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 MEMBER: 1. The present appeal

JOINT COMMISSIONER OF INCOME TAX, SUBHASH ROAD DEHADUN vs. M/S TIMES SQUARE, SAHASTRADHARA ROAD

In the result, appeal of the Revenue is dismissed

TDS 2015-16\n5000000.00\n(AS PER ANNEXURE C)\nADVANCE SHOPS UNITS\n12961.00\n(AS PER ANNEXURE D)\nADVANCE TAX\n50000.00\nMUKTA ARTS\n400000.00\nSECURITY DEPOSITS\n5756742.00 SERVICE TAX RECEIVABLE (13-14)\n66595.00\n\nADVANCE TO SUPPLIERS\n3015877.15\nPROVISIONS\nTDS PAYABLE\n120943.00 (AS PER ANNEXURE 'F')-\nSERVICE TAX PAYABLE\n371622.00-\nAUDIT FEES PAYABLE\n34500.00\nVAT PAYABLE\n111000.00\n120379378.15\n120379378.15\nDuring

DY. COMMISSIONER OF INCOME TAX, DEHRADUN vs. HALLIBURTON OFF SHORE SERVICES INC , MAHARASHTRA

In the result, ground no.3 is allowed

Bench: Shri Yogesh Kumar Us & Shri Sanjay Awasthiआ.अ.सं/.I.T.A No.241/Ddn/2025 िनधा"रणवष"/Assessment Year:2021-22 बनाम Dy. Commissioner Of Income Halliburton Off Shore Services Inc.,Unit No.603, 6Th Floor, Tax, Vs. Aayakar Bhawan, 13-A, Subhash Satellite Gazebo, East Wing,Guru Road, Hargovindji Marg,Andheri Mumbai, Navi Dehradun, Uttarakhand. Mumbai,Maharashtra. Pan No.Aaach5154M अपीलाथ" Appellant ""यथ"/Respondent

13-A, Subhash Satellite Gazebo, East Wing,Guru Road, Hargovindji Marg,Andheri Mumbai, Navi Dehradun, Uttarakhand. Mumbai,Maharashtra. PAN No.AAACH5154M अपीलाथ" Appellant ""यथ"/Respondent Shri Amit Arora, CA & Assessee by Shri Vishal Mishra, CA Revenue by Shri Mohan Lal Joshi, Sr. DR सुनवाईक"तारीख/ Date of hearing: 09.02.2026 11.02.2026 उ"ोषणाक"तारीख/Pronouncement on आदेश /O R D

DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE), DEHRADUN, DEHRADUN vs. STONEFIELD CONSTRUCTION, DEHRADUN, DEHRADUN

In the result, appeal of the Revenue is partly allowed

TDS is required to be made on the net amount of purchases i.e. net of GST and if the amount of GST is reduced from gross value of purchases, the net amount of purchases made from M/s Tripura Enterprises reduced to INR 45,72,020/- which is less than the threshold limit of INR 50.00 as provided in section 194Q

ACIT, CIRCLE- 2, INTERNATIONAL TAXATION, DEHRADUN vs. SOLAR TURBINES INTERNATIONAL CO., BENGALURU

In the result, the appeal of the Revenue is dismissed

Bench: Dr. B.R.R. Kumar & Sh. Yogesh Kumar U.S.Assessment Year: 2014-15 Solar Turbines International Vs Dcit, Company (Singapore Branch Of Circle-2, Solar Turbines International International Taxation, Company, Usa), Dehradun. 14 Tractor Road, Singapore, C/O Delloitte Haskins & Sells Llp, Deloitte Centre Anchorage- Ii, Richmond Road, Bangalore. (Appellant) (Respondent) Pan No. Aajcs3585J Assessment Year: 2014-15

d) The learned CIT(A) erred in not following the binding decision of the jurisdictional Honourable Income Tax Appellate Tribunal, Delhi in the case of OSRAM India Pvt. Ltd. vs. DCIT, CPC-TDS [ITA 4052/Del/2015. 2. The assessee has raised the issue of levy of surcharge and education cess. This issue is no longer res integra as amended involved

ONGC AS REPRESENTATIVE ASSESSEE OF UNIVERSITY OF CALGARY, ALBERTA, CANADA,DEHRADUN vs. DCIT (INTERNATIONAL TAXATION), DEHRADUN

In the result, all the appeals of the assessee are allowed

Bench: Sh. Kul Bharatdr. B. R. R. Kumarita No. 5865/Del/2010 : Asstt. Year : 2007-08

section 90(2) of the Act, where a DTAA exists, the provisions of the Act continue to apply vis-a-vis those of the DTAA, to the extent they are more beneficial to the assessee. In the instant case, the non-resident is a tax resident of Canada and is, therefore, entitled to be governed by the provisions of DTAA

ONGC AS REPRESENTATIVE ASSESSEE OF UNIVERSITY OF CALGARY, ALBERTA, CANADA,DEHRADUN vs. ADIT, DEHRADUN

In the result, all the appeals of the assessee are allowed

Bench: Sh. Kul Bharatdr. B. R. R. Kumarita No. 5865/Del/2010 : Asstt. Year : 2007-08

section 90(2) of the Act, where a DTAA exists, the provisions of the Act continue to apply vis-a-vis those of the DTAA, to the extent they are more beneficial to the assessee. In the instant case, the non-resident is a tax resident of Canada and is, therefore, entitled to be governed by the provisions of DTAA

ONGC AS REPRESENTATIVE ASSESSEE OF SHELL GLOBAL SOLUTIONS INTL., B.V., NETHERLANDS.,DEHRADUN vs. ADIT, DEHRADUN

In the result, all the appeals of the assessee are allowed

Bench: Sh. Kul Bharatdr. B. R. R. Kumarita No. 5865/Del/2010 : Asstt. Year : 2007-08

section 90(2) of the Act, where a DTAA exists, the provisions of the Act continue to apply vis-a-vis those of the DTAA, to the extent they are more beneficial to the assessee. In the instant case, the non-resident is a tax resident of Canada and is, therefore, entitled to be governed by the provisions of DTAA

ONGC AS REPRESENTATIVE ASSESSEE OF CHEMICAL MARKET ASSOCIATES INC., EUROPE LTD.,DEHRADUN vs. ADIT, DEHRADUN

In the result, all the appeals of the assessee are allowed

Bench: Sh. Kul Bharatdr. B. R. R. Kumarita No. 5865/Del/2010 : Asstt. Year : 2007-08

section 90(2) of the Act, where a DTAA exists, the provisions of the Act continue to apply vis-a-vis those of the DTAA, to the extent they are more beneficial to the assessee. In the instant case, the non-resident is a tax resident of Canada and is, therefore, entitled to be governed by the provisions of DTAA