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

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

2. The learned counsel appearing on either side would submit that the Judgment of this Court reported in 2023 (10) TMI 1141 [ M/s. True Blue Voice India Private Ltd., and another Vs. the Chief Commissioner of Income Tax - TDS, Chennai and others] would squarely apply to the facts of the present case. 3. The relevant portion of the said Judgment

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

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

2. The learned counsel appearing on either side would submit that the Judgment of this Court reported in 2023 (10) TMI 1141 [ M/s. True Blue Voice India Private Ltd., and another Vs. the Chief Commissioner of Income Tax - TDS, Chennai and others] would squarely apply to the facts of the present case. 3. The relevant portion of the said Judgment

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

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

2. The learned counsel appearing on either side would submit that the Judgment of this Court reported in 2023 (10) TMI 1141 [ M/s. True Blue Voice India Private Ltd., and another Vs. the Chief Commissioner of Income Tax - TDS, Chennai and others] would squarely apply to the facts of the present case. 3. The relevant portion of the said Judgment

CHIEF EDUCATION OFFICER,DEHRADUN vs. CIT (AI, DEHRADUN

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

2. The learned counsel appearing on either side would submit that the Judgment of this Court reported in 2023 (10) TMI 1141 [ M/s. True Blue Voice India Private Ltd., and another Vs. the Chief Commissioner of Income Tax - TDS, Chennai and others] would squarely apply to the facts of the present case. 3. The relevant portion of the said Judgment

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

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

2. The learned counsel appearing on either side would submit that the Judgment of this Court reported in 2023 (10) TMI 1141 [ M/s. True Blue Voice India Private Ltd., and another Vs. the Chief Commissioner of Income Tax - TDS, Chennai and others] would squarely apply to the facts of the present case. 3. The relevant portion of the said Judgment

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

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

2. The learned counsel appearing on either side would submit that the Judgment of this Court reported in 2023 (10) TMI 1141 [ M/s. True Blue Voice India Private Ltd., and another Vs. the Chief Commissioner of Income Tax - TDS, Chennai and others] would squarely apply to the facts of the present case. 3. The relevant portion of the said Judgment

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

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

2. The learned counsel appearing on either side would submit that the Judgment of this Court reported in 2023 (10) TMI 1141 [ M/s. True Blue Voice India Private Ltd., and another Vs. the Chief Commissioner of Income Tax - TDS, Chennai and others] would squarely apply to the facts of the present case. 3. The relevant portion of the said Judgment

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

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

2. The learned counsel appearing on either side would submit that the Judgment of this Court reported in 2023 (10) TMI 1141 [ M/s. True Blue Voice India Private Ltd., and another Vs. the Chief Commissioner of Income Tax - TDS, Chennai and others] would squarely apply to the facts of the present case. 3. The relevant portion of the said Judgment

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- II, INTL. TAXATION, DEHRADUN vs. R & B FALCON (A) PTY LTD., DEHRADUN

In the result, appeal of the revenue is dismissed

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

17. The Court accordingly holds that for the purposes of computing the ‘presumptive income’ of the assessee for the purposes of Section 44 BB of the Act, the service tax collected by the Assessee on the amount paid t it for rendering services is not to be included in the gross receipts in terms of Section 44 BB (2) read

DCIT, CIRCLE- II, INTL. TAXATION, DEHRADUN vs. R & B FALCON (A) PTY LTD., DEHRADUN

In the result, appeal of the revenue is dismissed

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

17. The Court accordingly holds that for the purposes of computing the ‘presumptive income’ of the assessee for the purposes of Section 44 BB of the Act, the service tax collected by the Assessee on the amount paid t it for rendering services is not to be included in the gross receipts in terms of Section 44 BB (2) read

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

In the result, appeal of the revenue is dismissed

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

17. The Court accordingly holds that for the purposes of computing the ‘presumptive income’ of the assessee for the purposes of Section 44 BB of the Act, the service tax collected by the Assessee on the amount paid t it for rendering services is not to be included in the gross receipts in terms of Section 44 BB (2) read

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

17. The Court accordingly holds that for the purposes of computing the ‘presumptive income’ of the assessee for the purposes of Section 44 BB of the Act, the service tax collected by the Assessee on the amount paid t it for rendering services is not to be included in the gross receipts in terms of Section 44 BB (2) read

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

17. The Court accordingly holds that for the purposes of computing the ‘presumptive income’ of the assessee for the purposes of Section 44 BB of the Act, the service tax collected by the Assessee on the amount paid t it for rendering services is not to be included in the gross receipts in terms of Section 44 BB (2) read

DCIT, CIRCLE-II, INTL. TAXATION, DEHRADUN vs. TRITON HOLDINGS LTD., DEHRADUNA

In the result, appeals of the revenue are dismissed

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

17. The Court accordingly holds that for the purposes of computing the ‘presumptive income’ of the assessee for the purposes of Section 44 BB of the Act, the service tax collected by the Assessee on the amount paid t it for rendering services is not to be included in the gross receipts in terms of Section 44 BB (2) read

DCIT, CIRCLE-II, INTL. TAXATION, DEHRADUN vs. TRITON HOLDINGS LTD., DEHRADUNA

In the result, appeals of the revenue are dismissed

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

17. The Court accordingly holds that for the purposes of computing the ‘presumptive income’ of the assessee for the purposes of Section 44 BB of the Act, the service tax collected by the Assessee on the amount paid t it for rendering services is not to be included in the gross receipts in terms of Section 44 BB (2) read

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

17. In CIT v. Lakshmi Machine Works (supra), the Supreme Court approved the decision of the Bombay High Court in CIT v. Sudarshan Chemicals Industries Ltd. (supra) which in turn considered the decision of the Supreme Court in George Oakes 13 ITA No.6001.Del.2017 Deepwater Pacific 1 Inc. (P) Ltd. (supra). In the considered view of the Court, the decision

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

17. In CIT v. Lakshmi Machine Works (supra), the Supreme Court approved the decision of the Bombay High Court in CIT v. Sudarshan Chemicals Industries Ltd. (supra) which in turn considered the decision of the Supreme Court in George Oakes (P) Ltd. (supra). In the considered view of the Court, the decision of the Supreme Court in Lakshmi Machines Works

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

17. In CIT v. Lakshmi Machine Works (supra), the Supreme Court approved the decision of the Bombay High Court in CIT v. Sudarshan Chemicals Industries Ltd. (supra) which in turn considered the decision of the Supreme Court in George Oakes (P) Ltd. (supra). In the considered view of the Court, the decision of the Supreme Court in Lakshmi Machines Works