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12 results for “TDS”+ Section 193clear

Sorted by relevance

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Key Topics

Section 44B30Section 914Section 9(1)(vii)8Addition to Income8Section 2637Section 405Section 143(3)4Permanent Establishment4Business Income4Double Taxation/DTAA

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

Appeal is allowed

ITA 45/DDN/2024[2012-13]Status: DisposedITAT Dehradun13 Jun 2025AY 2012-13

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

Section 11Section 12ASection 194Section 194JSection 2(15)Section 40

TDS on certain amounts to which the various provisions of Sections 193 & 194 were applicable. The Assessing Officer held that

4
Section 113
Section 12A3

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 5583/DEL/2013[2007-08]Status: DisposedITAT Dehradun08 Jun 2021AY 2007-08

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

193,673,644, are taxable under section 44BB of the Act, as opposed to the Appellant‟s claim of non-taxability of the same . 3. The learned CIT(A) has erred in not accepting a without prejudice claim of the Appellant that 2% of revenues from supply of imported material should be taxed in India. 4. The learned

MI OVERSEAS LTD.,NEW DELHI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 3072/DEL/2012[2009-10]Status: DisposedITAT Dehradun08 Jun 2021AY 2009-10

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

193,673,644, are taxable under section 44BB of the Act, as opposed to the Appellant‟s claim of non-taxability of the same . 3. The learned CIT(A) has erred in not accepting a without prejudice claim of the Appellant that 2% of revenues from supply of imported material should be taxed in India. 4. The learned

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

ITA 3045/DEL/2013[2006-07]Status: DisposedITAT Dehradun08 Jun 2021AY 2006-07

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

193,673,644, are taxable under section 44BB of the Act, as opposed to the Appellant‟s claim of non-taxability of the same . 3. The learned CIT(A) has erred in not accepting a without prejudice claim of the Appellant that 2% of revenues from supply of imported material should be taxed in India. 4. The learned

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

ITA 5564/DEL/2013[2007-08]Status: DisposedITAT Dehradun08 Jun 2021AY 2007-08

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

193,673,644, are taxable under section 44BB of the Act, as opposed to the Appellant‟s claim of non-taxability of the same . 3. The learned CIT(A) has erred in not accepting a without prejudice claim of the Appellant that 2% of revenues from supply of imported material should be taxed in India. 4. The learned

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 5584/DEL/2013[2010-11]Status: DisposedITAT Dehradun08 Jun 2021AY 2010-11

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

193,673,644, are taxable under section 44BB of the Act, as opposed to the Appellant‟s claim of non-taxability of the same . 3. The learned CIT(A) has erred in not accepting a without prejudice claim of the Appellant that 2% of revenues from supply of imported material should be taxed in India. 4. The learned

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

ITA 5565/DEL/2013[2010-11]Status: DisposedITAT Dehradun08 Jun 2021AY 2010-11

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

193,673,644, are taxable under section 44BB of the Act, as opposed to the Appellant‟s claim of non-taxability of the same . 3. The learned CIT(A) has erred in not accepting a without prejudice claim of the Appellant that 2% of revenues from supply of imported material should be taxed in India. 4. The learned

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 2956/DEL/2013[2006-07]Status: DisposedITAT Dehradun08 Jun 2021AY 2006-07

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

193,673,644, are taxable under section 44BB of the Act, as opposed to the Appellant‟s claim of non-taxability of the same . 3. The learned CIT(A) has erred in not accepting a without prejudice claim of the Appellant that 2% of revenues from supply of imported material should be taxed in India. 4. The learned

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

ITA 6126/DEL/2017[2013-14]Status: DisposedITAT Dehradun15 Sept 2023AY 2013-14

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

For Appellant: Shri P. J. Pardiwalla, Sr. AdvFor Respondent: Shri Mayank Kumar, JCIT, DR
Section 143(3)Section 44BSection 9(1)(vii)

193,32,02,920/-. 4.3. We find that there is absolutely no dispute that the assessee is engaged in the business of exploration of mineral oils. We find that the assessee had offered income on presumptive basis by applying the provisions of section 44BB(1) of the Act. It is not in dispute that the activities carried

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

ITA 5305/DEL/2018[2015-16]Status: DisposedITAT Dehradun15 Sept 2023AY 2015-16

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

For Appellant: Shri P. J. Pardiwalla, Sr. AdvFor Respondent: Shri Mayank Kumar, JCIT, DR
Section 143(3)Section 44BSection 9(1)(vii)

193,32,02,920/-. 4.3. We find that there is absolutely no dispute that the assessee is engaged in the business of exploration of mineral oils. We find that the assessee had offered income on presumptive basis by applying the provisions of section 44BB(1) of the Act. It is not in dispute that the activities carried

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

ITA 6173/DEL/2017[2014-15]Status: DisposedITAT Dehradun15 Sept 2023AY 2014-15

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

For Appellant: Shri P. J. Pardiwalla, Sr. AdvFor Respondent: Shri Mayank Kumar, JCIT, DR
Section 143(3)Section 44BSection 9(1)(vii)

193,32,02,920/-. 4.3. We find that there is absolutely no dispute that the assessee is engaged in the business of exploration of mineral oils. We find that the assessee had offered income on presumptive basis by applying the provisions of section 44BB(1) of the Act. It is not in dispute that the activities carried

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

ITA 5223/DEL/2018[2015-16]Status: DisposedITAT Dehradun15 Sept 2023AY 2015-16

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

For Appellant: Shri P. J. Pardiwalla, Sr. AdvFor Respondent: Shri Mayank Kumar, JCIT, DR
Section 143(3)Section 44BSection 9(1)(vii)

193,32,02,920/-. 4.3. We find that there is absolutely no dispute that the assessee is engaged in the business of exploration of mineral oils. We find that the assessee had offered income on presumptive basis by applying the provisions of section 44BB(1) of the Act. It is not in dispute that the activities carried