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

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

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

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

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

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

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

BG INTERNATIONAL 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 and stay application filed by the assessee is dismissed

Bench: Shri R.K. Panda & Ms Suchitra Kambleasstt. Year 2017-18

D E R PER R.K. PANDA, AM This appeal filed by the assesssee is directed against the order dated 23.06.2020 passed u/s 143(3) r.w.s. 144C(13) of the I.T. Act 1961 for the assessment year 2017-18. 2. Facts of the case, in brief, are that the assessee is a group entity of BG Group

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

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

D E R PER B.R.R.KUMAR, ACCOUNTANT MEMBER : This appeal has been filed by the revenue against the order of the ld. CIT(A)-2, Noida, dated 27.07.2017. 2. The only issue involved in this case is that whether service tax is includable in the gross revenue for computing profits under presumptive provisions of section 44BB

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

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

D E R PER B.R.R.KUMAR, ACCOUNTANT MEMBER : Both appeals have been filed by the revenue against the order of the ld. CIT(A)-2, Noida, dated 27.07.2017. 2. The only issue involved in this case is that whether service tax is includable in the gross revenue for computing profits under presumptive provisions of section 44BB

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

D E R PER B.R.R.KUMAR, ACCOUNTANT MEMBER : Both appeals have been filed by the revenue against the order of the ld. CIT(A)-2, Noida, dated 27.07.2017. 2. The only issue involved in this case is that whether service tax is includable in the gross revenue for computing profits under presumptive provisions of section 44BB