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16 results for “TDS”+ Section 195(3)clear

Sorted by relevance

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Key Topics

Section 44B32Section 9(1)(vii)14Section 914Double Taxation/DTAA9Addition to Income9Section 143(3)8Permanent Establishment8Section 2637Section 115A4Business Income

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

195 of the income tax act and therefore not required to pay interest u/s 234B & 234C of the act. 58. Ground number 10 and 11 are with respect to the initiation of the penalty proceedings u/s 271 (1) (c) and Section 271B of the act. As the learned assessing officer has merely initiated the penalty proceedings, these grounds of appeal

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

4
Section 9(1)(vi)3

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

195 of the income tax act and therefore not required to pay interest u/s 234B & 234C of the act. 58. Ground number 10 and 11 are with respect to the initiation of the penalty proceedings u/s 271 (1) (c) and Section 271B of the act. As the learned assessing officer has merely initiated the penalty proceedings, these grounds of appeal

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

195 of the income tax act and therefore not required to pay interest u/s 234B & 234C of the act. 58. Ground number 10 and 11 are with respect to the initiation of the penalty proceedings u/s 271 (1) (c) and Section 271B of the act. As the learned assessing officer has merely initiated the penalty proceedings, these grounds of appeal

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

195 of the income tax act and therefore not required to pay interest u/s 234B & 234C of the act. 58. Ground number 10 and 11 are with respect to the initiation of the penalty proceedings u/s 271 (1) (c) and Section 271B of the act. As the learned assessing officer has merely initiated the penalty proceedings, these grounds of appeal

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

195 of the income tax act and therefore not required to pay interest u/s 234B & 234C of the act. 58. Ground number 10 and 11 are with respect to the initiation of the penalty proceedings u/s 271 (1) (c) and Section 271B of the act. As the learned assessing officer has merely initiated the penalty proceedings, these grounds of appeal

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

195 of the income tax act and therefore not required to pay interest u/s 234B & 234C of the act. 58. Ground number 10 and 11 are with respect to the initiation of the penalty proceedings u/s 271 (1) (c) and Section 271B of the act. As the learned assessing officer has merely initiated the penalty proceedings, these grounds of appeal

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

195 of the income tax act and therefore not required to pay interest u/s 234B & 234C of the act. 58. Ground number 10 and 11 are with respect to the initiation of the penalty proceedings u/s 271 (1) (c) and Section 271B of the act. As the learned assessing officer has merely initiated the penalty proceedings, these grounds of appeal

DY. COMMISSIONER OF INCOME TAX, DEHRADUN vs. HALLIBURTON WORLDWIDE GMBH, DEHRADUN

In the result, the appeal is dismissed

ITA 250/DDN/2025[2016-17]Status: DisposedITAT Dehradun18 Feb 2026AY 2016-17

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

Section 115ASection 250Section 9(1)(vi)

3 pertaining to the issue of license to use proprietary software, we support the funding of Ld. CIT(A) (supra), especially also following the judgment rendered by the Hon’ble Apex Court in the case of Engineering Analysis Centre of Excellence (P) Ltd. (supra), whereby the issue has been decided as under: - “CONCLUSION 168. Given the definition of royalties contained

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

ITA 83/DDN/2025[2022-23]Status: DisposedITAT Dehradun14 Jan 2026AY 2022-23

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

For Appellant: Sh. Nabin Ballodia, CA &For Respondent: Sh. Mohan Lal Joshi, Sr. DR
Section 143(3)Section 9(1)(vii)

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 holding it’s revenue derived from M/s ONGC Ltd. for undertaking construction activities for converting the latter’s oil rig namely “Sagar Samrat

GULF PIPING COMPANY WLL,UNITED ARAB EMIRATES vs. DY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), DEHRADUN

ITA 81/DDN/2024[2020-21]Status: DisposedITAT Dehradun14 Jan 2026AY 2020-21

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

For Appellant: Sh. Nabin Ballodia, CA &For Respondent: Sh. Mohan Lal Joshi, Sr. DR
Section 143(3)Section 9(1)(vii)

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 holding it’s revenue derived from M/s ONGC Ltd. for undertaking construction activities for converting the latter’s oil rig namely “Sagar Samrat

GULF PIPING COMPANY WLL,UNITED ARAB EMIRATES vs. DY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), DEHRADUN

ITA 71/DDN/2024[2021-22]Status: DisposedITAT Dehradun14 Jan 2026AY 2021-22

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

For Appellant: Sh. Nabin Ballodia, CA &For Respondent: Sh. Mohan Lal Joshi, Sr. DR
Section 143(3)Section 9(1)(vii)

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 holding it’s revenue derived from M/s ONGC Ltd. for undertaking construction activities for converting the latter’s oil rig namely “Sagar Samrat

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)

195/- and offered to tax u/s 44BB of the Act on presumptive basis @ 10% of receipts amounting to Rs 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

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)

195/- and offered to tax u/s 44BB of the Act on presumptive basis @ 10% of receipts amounting to Rs 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

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)

195/- and offered to tax u/s 44BB of the Act on presumptive basis @ 10% of receipts amounting to Rs 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

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)

195/- and offered to tax u/s 44BB of the Act on presumptive basis @ 10% of receipts amounting to Rs 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

SERCEL SA ,DEHRADUN vs. DCIT, CIRCLE-2, DDN, DEHRADUN

In the result, the appeal of the assessee is allowed

ITA 59/DDN/2023[2020-21]Status: DisposedITAT Dehradun13 Mar 2026AY 2020-21

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

Section 142(1)Section 143(3)Section 195Section 44BSection 9(1)(i)

TDS was deducted by Oil and Natural Gas Corporation Limited (ONGS) u/s 195 of the Act, in it’s ITR. The assessee has reported an amount of Rs. 108,27,23,947/- as exempt in the Schedule EI: Exempt Income. In order to examine the veracity of the assessee’s claims, notices u/s 142(1) along with questionnaires were issued