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

144C(5)of the Act for the assessment year 2016-17. The assessee has raised the following grounds : Ground No. 1: Erroneous disallowance of payment made towards intra-group services by Appellant to its Associated Enterprise (“AE”) 1.1. The learned Transfer Pricing Officer ("TPO") / AO / DRP grossly erred in law and on facts by making an upward transfer pricing adjustment

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

144C(5) of the Income-tax Act, 1961 (“the Act”) on the following among other grounds. Ground No, 1: Erroneous disallowance of payment made towards intra- group services by Appellant to its Associated Enterprise (“AE”) 1.1 The learned Transfer Pricing Officer ("TPO") / AO / DRP grossly erred in law and on facts by making an upward transfer pricing adjustment

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

section 144C(13) of the Act on 30.01.2015 starting the computation of total income by taking the income as reflected in the audited profit and loss account of the assessee and determining the total income of the assessee at Rs. 2,72,23,425/-. 16. Aggrieved the assessee is in appeal before us. 17. The copy of contract entered into

SHERWATER GEOSERVICES LTD. INDIA PROJECT OFFICE,DEHRADUN vs. AICT, INTERNATIONAL TAXATION, CIRCLE-2, DEHRADUN, DEHRADUN

In the result, the appeal of the assessee is allowed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

144C(13) of the Income Tax Act, 1961. 2. The only issue involved in this case is that whether GST is includable in the gross revenue for computing profits under presumptive provisions of section 44BB of the I.T. Act, 1961 or not? 3. We have heard the rival submissions on the issue under consideration and have gone through the entire

SAEXPLORATION INC INDIA PROJECTS OFFICE,DEHRADUN vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION, CIRCLE-2, DEHRADUN, DEHRADUN

In the result, the appeal of the assessee is allowed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

144C(13) of the Income Tax Act, 1961. 2. The only issue involved in this case is that whether GST is includable in the gross revenue for computing profits under presumptive provisions of section 44BB of the I.T. Act, 1961 or not? 3. We have heard the rival submissions on the issue under consideration and have gone through the entire

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

144C(13) of the Income Tax Act, 1961 (in short “the Act”), respectively. 2. Heard both the parties at length. Case files perused. 3. It transpires during the course of hearing that the assessee raises it’s identical sole substantive grievance in the former twin assessment years 2020-21 and 2021-22 seeking to reverse the learned lower authorities’ action

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

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

144C(13) of the Income Tax Act, 1961 (in short “the Act”), respectively. 2. Heard both the parties at length. Case files perused. 3. It transpires during the course of hearing that the assessee raises it’s identical sole substantive grievance in the former twin assessment years 2020-21 and 2021-22 seeking to reverse the learned lower authorities’ action

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

144C(13) of the Income Tax Act, 1961 (in short “the Act”), respectively. 2. Heard both the parties at length. Case files perused. 3. It transpires during the course of hearing that the assessee raises it’s identical sole substantive grievance in the former twin assessment years 2020-21 and 2021-22 seeking to reverse the learned lower authorities’ action

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

144C(3) of the Act dated 14.01.2019 wherein the same services were ITA No. 6126/Del/2017 & ITA No. 5223/Del/2018 (Assessee) ITA No. 6173/Del/2017 & ITA No. 5305/Del/2018 (Revenue) Schlumberger Asia Services Ltd accepted by the ld. AO to be taxable u/s 44BB of the Act by following the decision of Hon’ble Supreme Court in the case of ONGC Ltd referred supra

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

144C(3) of the Act dated 14.01.2019 wherein the same services were ITA No. 6126/Del/2017 & ITA No. 5223/Del/2018 (Assessee) ITA No. 6173/Del/2017 & ITA No. 5305/Del/2018 (Revenue) Schlumberger Asia Services Ltd accepted by the ld. AO to be taxable u/s 44BB of the Act by following the decision of Hon’ble Supreme Court in the case of ONGC Ltd referred supra

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

144C(3) of the Act dated 14.01.2019 wherein the same services were ITA No. 6126/Del/2017 & ITA No. 5223/Del/2018 (Assessee) ITA No. 6173/Del/2017 & ITA No. 5305/Del/2018 (Revenue) Schlumberger Asia Services Ltd accepted by the ld. AO to be taxable u/s 44BB of the Act by following the decision of Hon’ble Supreme Court in the case of ONGC Ltd referred supra

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

144C(3) of the Act dated 14.01.2019 wherein the same services were ITA No. 6126/Del/2017 & ITA No. 5223/Del/2018 (Assessee) ITA No. 6173/Del/2017 & ITA No. 5305/Del/2018 (Revenue) Schlumberger Asia Services Ltd accepted by the ld. AO to be taxable u/s 44BB of the Act by following the decision of Hon’ble Supreme Court in the case of ONGC Ltd referred supra