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42 results for “TDS”+ Section 2(14)clear

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Key Topics

Section 200A112Section 44B52Section 234E40Section 143(3)29Addition to Income17TDS17Section 271C13Section 153C12Disallowance10Double Taxation/DTAA

DR. VIRENDRA SWAROOP EDUCATIONAL FOUNDATION,KANPUR vs. ACIT, CENTRAL CIRCLE, DEHRADUN, DEHRADUN

In the result, appeal of the assessee is allowed

ITA 211/DDN/2025[2023-24]Status: DisposedITAT Dehradun16 Jan 2026AY 2023-24

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.

Section 11Section 12Section 127Section 12ASection 12A(1)(ac)Section 132Section 143(3)

2. That on the facts and circumstances of the case and in law, the order passed by PCIT under section 12AB(4)(ii) of the Act cancelling the registration of the Appellant trust is illegal, bad in law and without jurisdiction. 3. That the reference made by the Assessing Officer ('AO') under the second proviso to Section 143(3) read

Showing 1–20 of 42 · Page 1 of 3

10
Section 12A8
Section 9(1)(vii)8

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

ITA 45/DDN/2023[2015-16]Status: DisposedITAT Dehradun27 Jan 2025AY 2015-16

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

Section 200Section 200ASection 234E

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

ITA 51/DDN/2023[2016-17]Status: DisposedITAT Dehradun27 Jan 2025AY 2016-17

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

Section 200Section 200ASection 234E

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

ITA 46/DDN/2023[2015-16]Status: DisposedITAT Dehradun27 Jan 2025AY 2015-16

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

Section 200Section 200ASection 234E

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

ITA 48/DDN/2023[2016-17]Status: DisposedITAT Dehradun27 Jan 2025AY 2016-17

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

Section 200Section 200ASection 234E

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

ITA 44/DDN/2023[2015-16]Status: DisposedITAT Dehradun27 Jan 2025AY 2015-16

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

Section 200Section 200ASection 234E

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

ITA 47/DDN/2023[2015-16]Status: DisposedITAT Dehradun27 Jan 2025AY 2015-16

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

Section 200Section 200ASection 234E

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

ITA 49/DDN/2023[2016-17]Status: DisposedITAT Dehradun27 Jan 2025AY 2016-17

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

Section 200Section 200ASection 234E

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

ITA 50/DDN/2023[2016-17]Status: DisposedITAT Dehradun27 Jan 2025AY 2016-17

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

Section 200Section 200ASection 234E

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

ITA 6437/DEL/2014[2011-12]Status: DisposedITAT Dehradun05 May 2022AY 2011-12

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

Section 143(3)Section 44BSection 44DSection 9

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

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

ITA 6/DDN/2023[2020-21]Status: DisposedITAT Dehradun27 Oct 2023AY 2020-21

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

For Appellant: Sh. Sanjay Aggarwal, CAFor Respondent: Sh. A. S. Rana, Sr. DR
Section 143(3)Section 44B

14. In the considered view of the Court, both the aforementioned decisions were rendered in the specific contexts in which the questions arose before the Court. In other words the interpretation placed by the Court on the expression “trading receipt’ or ‘turnover’ in the said decisions was determined by the context. The later decision of the Supreme Court

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

ITA 5/DDN/2023[2020-21]Status: DisposedITAT Dehradun27 Oct 2023AY 2020-21

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

For Appellant: Sh. Taran Preet Singh, CAFor Respondent: Sh. A. S. Rana, Sr. DR
Section 143(3)Section 44B

14. In the considered view of the Court, both the aforementioned decisions were rendered in the specific contexts in which the questions arose before the Court. In other words the interpretation placed by the Court on the expression “trading receipt’ or ‘turnover’ in the said decisions was determined by the context. The later decision of the Supreme Court

MB PETROLEUM SERVICES LLC,MUMBAI vs. DDIT, DEHRADUN

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 1828/DEL/2015[2011-12]Status: DisposedITAT Dehradun15 Sept 2023AY 2011-12

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

For Appellant: Smt Shashi M. Kapila, AdvFor Respondent: Sh. Mayank Kumar, JCIT, DR
Section 143(3)Section 32Section 44B

2 to 11 raised by the assessee are allowed and additional ground raised by the assessee is allowed. 26. With regard to ground raised in seeking correct credit for TDS, the same requires factual verification and hence Ld AO is directed to give credit for TDS in accordance with law. Accordingly, the ground no12 raised by the assessee is allowed

DY. COMMISSIONER OF INCOME TAX, DEHRADUN vs. HALLIBURTON OFF SHORE SERVICES INC , MAHARASHTRA

In the result, ground no.3 is allowed

ITA 241/DDN/2025[2021-22]Status: DisposedITAT Dehradun11 Feb 2026AY 2021-22

Bench: Shri Yogesh Kumar Us & Shri Sanjay Awasthiआ.अ.सं/.I.T.A No.241/Ddn/2025 िनधा"रणवष"/Assessment Year:2021-22 बनाम Dy. Commissioner Of Income Halliburton Off Shore Services Inc.,Unit No.603, 6Th Floor, Tax, Vs. Aayakar Bhawan, 13-A, Subhash Satellite Gazebo, East Wing,Guru Road, Hargovindji Marg,Andheri Mumbai, Navi Dehradun, Uttarakhand. Mumbai,Maharashtra. Pan No.Aaach5154M अपीलाथ" Appellant ""यथ"/Respondent

Section 19Section 194CSection 194JSection 250Section 40

section of TDS has been put to rest by the Hon’ble jurisdictional Uttarakhand HC vide its order in the case of CIT v. Samsung Heavy Industries Company Limited(supra). Therefore, respectfully following the judicial ratio laid down by the jurisdictional High Court, disallowance of Rs.4,47,53,145/- is deleted. The ground of appeal is allowed in favor

M.B. PETROLEUM SERVICES LLC,NEW DELHI vs. DCIT (INTERNATIONAL TAXATION), DEHRADUN

In the result, the appeal of the assessee is allowed

ITA 6608/DEL/2016[2012-13]Status: DisposedITAT Dehradun05 Oct 2023AY 2012-13
For Appellant: Smt. Shashi M Kapila, AdvocateFor Respondent: Shri Mayank Kumar, Addl.CIT DR
Section 143(3)Section 246ASection 271GSection 40aSection 44BSection 44D

TDS has been deducted”. (Disallowance of Rs. 10,78,358/-) 5 ITA No.6608/Del./2016 (iii) The assessee's written submission vide their reply dated 16.11.2015, with regard to disallowance made as per para 5.1 of the draft assessment order regarding "Depreciation and Amortization expenses" of Rs.49,86,844/-, has been perused and found not acceptable. The assessee could not prove

YES BANK LTD.,MUMBAI vs. ADDL. CIT (TDS), DEHRADUN

In the result, the appeals of the assessee are allowed

ITA 7499/DEL/2017[2014-15]Status: DisposedITAT Dehradun15 Dec 2022AY 2014-15

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usita No. 7498/Del/2017 : Asstt. Year : 2013-14 Ita No. 7499/Del/2017 : Asstt. Year : 2014-15

For Appellant: NoneFor Respondent: Smt. Mayank Prabha Tomar, Addl. CIT
Section 194ASection 194A(3)(iii)Section 201Section 201(1)Section 271Section 271CSection 274Section 4

2) of the Act, by the income tax department. • UEPPCB relied on the notification dated 19.12.2005 issued by die Ministry of Environment and Forests to Central Board of Direct • Taxes, Department of Revenue, Ministry of Finance on die subject, 'Exemption to State Pollution Control Boards' from filing income tax Returns. The relevant extracts from the above letter is reproduced below

YES BANK LTD.,MUMBAI vs. ADDL. CIT (TDS), DEHRADUN

In the result, the appeals of the assessee are allowed

ITA 7498/DEL/2017[2013-14]Status: DisposedITAT Dehradun15 Dec 2022AY 2013-14

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usita No. 7498/Del/2017 : Asstt. Year : 2013-14 Ita No. 7499/Del/2017 : Asstt. Year : 2014-15

For Appellant: NoneFor Respondent: Smt. Mayank Prabha Tomar, Addl. CIT
Section 194ASection 194A(3)(iii)Section 201Section 201(1)Section 271Section 271CSection 274Section 4

2) of the Act, by the income tax department. • UEPPCB relied on the notification dated 19.12.2005 issued by die Ministry of Environment and Forests to Central Board of Direct • Taxes, Department of Revenue, Ministry of Finance on die subject, 'Exemption to State Pollution Control Boards' from filing income tax Returns. The relevant extracts from the above letter is reproduced below

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)

14 raised by the revenue is general in nature and does not require any specific adjudication. 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 10. Now we are left with Ground No. 5 raised by the assessee for the Asst Year 2015-16 regarding the taxability of interest on income

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)

14 raised by the revenue is general in nature and does not require any specific adjudication. 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 10. Now we are left with Ground No. 5 raised by the assessee for the Asst Year 2015-16 regarding the taxability of interest on income

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)

14 raised by the revenue is general in nature and does not require any specific adjudication. 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 10. Now we are left with Ground No. 5 raised by the assessee for the Asst Year 2015-16 regarding the taxability of interest on income