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

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Key Topics

Section 44B131Addition to Income17Section 915Section 143(3)13Deduction13Section 271C8Section 194A8Exemption8Disallowance8Section 263

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

iii. Receipts on account of reimbursement of service tax from PSC and Non-PSC included in the revenue chargeable to tax (under section 44BB and section 44DA respectively depending on the stream of income) as opposed to not chargeable to tax claimed in the ROI; and iv. Receipts on account of reimbursement of expenditure (equipment lost in hole, customs duty

Showing 1–20 of 32 · Page 1 of 2

7
Section 2016
Section 44D4

DCIT, CIRCLE- 1, INTERNATIONAL TAXATION, DEHRADUN vs. TRANSOCEAN OFFSHORE DEEPWATER DRILLING INC, DEHRADUN

In the result, appeal of the revenue is dismissed

ITA 6175/DEL/2017[2013-14]Status: DisposedITAT Dehradun22 Nov 2021AY 2013-14

Bench: Shri Amit Shukladr. B.R.R. Kumar

For Appellant: Sh. Amit Arora, AdvFor Respondent: Sh. T.S.Mapwal, Sr. DR
Section 44B

iii) Once the receipts are offered to tax u / s 44BB (1) & (2), which provides for computation of profits on gross basis, there is no scope for computing or recomputing the profits by excluding any element of receipts from the total turnover as the same would amount to defeating the very purpose of providing for a scheme of simpler mode

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

In the result, appeal of the revenue is dismissed

ITA 6174/DEL/2017[2012-13]Status: DisposedITAT Dehradun22 Nov 2021AY 2012-13

Bench: Shri Amit Shukladr. B.R.R. Kumar

For Appellant: Sh. Amit Arora, AdvFor Respondent: Sh. T.S.Mapwal, Sr. DR
Section 44B

iii) Once the receipts are offered to tax u / s 44BB (1) & (2), which provides for computation of profits on gross basis, there is no scope for computing or recomputing the profits by excluding any element of receipts from the total turnover as the same would amount to defeating the very purpose of providing for a scheme of simpler mode

DCIT, CIRCLE- I, INTL. TAXATION, DEHRADUN vs. DEEPWATER PACIFIC 1 INC., DEHRADUN

In the result, appeal of the revenue is dismissed

ITA 6001/DEL/2017[2013-14]Status: DisposedITAT Dehradun22 Nov 2021AY 2013-14

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

For Appellant: Sh. Amit Arora, AdvFor Respondent: Sh. N.S.Jangpangi, CIT-DR
Section 44B

iii) Once the receipts are offered to tax u / s 44BB (1) & (2), which provides for computation of profits on gross basis, there is no scope for computing or recomputing the profits by excluding any element of receipts from the total turnover as the same would amount to defeating the very purpose of providing for a scheme of simpler mode

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

In the result, appeals of the revenue are dismissed

ITA 4640/DEL/2017[2014-15]Status: DisposedITAT Dehradun12 Nov 2021AY 2014-15

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

For Appellant: Shri Amit Arora, AdvFor Respondent: Sh. T.S. Mapwal, Sr. DR
Section 234BSection 44B

iii) Once the receipts are offered to tax u / s 44BB (1) & (2), which provides for computation of profits on gross basis, there is no scope for computing or recomputing the profits by excluding any element 7 ITA No.4639, 4640.Del.2017 M/s. Triton Holdings Limited of receipts from the total turnover as the same would amount to defeating the very

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

In the result, appeals of the revenue are dismissed

ITA 4639/DEL/2017[2012-13]Status: DisposedITAT Dehradun12 Nov 2021AY 2012-13

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

For Appellant: Shri Amit Arora, AdvFor Respondent: Sh. T.S. Mapwal, Sr. DR
Section 234BSection 44B

iii) Once the receipts are offered to tax u / s 44BB (1) & (2), which provides for computation of profits on gross basis, there is no scope for computing or recomputing the profits by excluding any element 7 ITA No.4639, 4640.Del.2017 M/s. Triton Holdings Limited of receipts from the total turnover as the same would amount to defeating the very

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

In the result, appeal of the revenue is dismissed

ITA 4653/DEL/2017[2014-15]Status: DisposedITAT Dehradun12 Nov 2021AY 2014-15

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

For Appellant: Shri Amit Arora, AdvFor Respondent: Sh. Narendra Singh Jangpangi, CIT- DR
Section 44B

iii) Once the receipts are offered to tax u / s 44BB (1) & (2), which provides for computation of profits on gross basis, there is no scope for computing or recomputing the profits by excluding any element of receipts from the total turnover as the same would amount to defeating the very purpose of providing for a scheme of simpler mode

DCIT, CIRCLE- II, (INTERNATIONAL TAXATION), DEHRADUN vs. SUNDOWNER OFFSHORE INTERNATIONAL (BERMUDA) LTD., DEHRADUN

In the result, appeal of the revenue is dismissed

ITA 4643/DEL/2017[2014-15]Status: DisposedITAT Dehradun22 Nov 2021AY 2014-15

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

For Appellant: Sh. Amit Arora, AdvFor Respondent: Sh. N.S. Jangpangi, CIT-DR
Section 44B

iii) Once the receipts are offered to tax u / s 44BB (1) & (2), which provides for computation of profits on gross basis, there is no scope for computing or recomputing the profits by excluding any element of receipts from the total turnover as the same would amount to defeating the very purpose of providing for a scheme of simpler mode

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

iii) Once the receipts are offered to tax u/s 44BB (1) & (2), which provides for computation of profits on gross basis, there is no scope for computing or re-computing the profits by excluding any element of receipts from the total turnover as the same would amount to defeating the very purpose of providing for a scheme of simpler mode

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

iii) Once the receipts are offered to tax u/s 44BB (1) & (2), which provides for computation of profits on gross basis, there is no scope for computing or re-computing the profits by excluding any element of receipts from the total turnover as the same would amount to defeating the very purpose of providing for a scheme of simpler mode

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

In the result, appeal of the revenue is dismissed

ITA 4642/DEL/2017[2013-14]Status: DisposedITAT Dehradun24 Nov 2021AY 2013-14

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

For Appellant: Sh. Amit Arora, AdvFor Respondent: Sh. T.S.Mapwal, Sr. DR
Section 44B

iii) Once the receipts are offered to tax u / s 44BB (1) & (2), which provides for computation of profits on gross basis, there is no scope for computing or recomputing the profits by excluding any element of receipts from the total turnover as the same would amount to defeating the very purpose of providing for a scheme of simpler mode

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

In the result, appeal of the revenue is dismissed

ITA 4641/DEL/2017[2012-13]Status: DisposedITAT Dehradun24 Nov 2021AY 2012-13

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

For Appellant: Sh. Amit Arora, AdvFor Respondent: Sh. T.S.Mapwal, Sr. DR
Section 44B

iii) Once the receipts are offered to tax u / s 44BB (1) & (2), which provides for computation of profits on gross basis, there is no scope for computing or recomputing the profits by excluding any element of receipts from the total turnover as the same would amount to defeating the very purpose of providing for a scheme of simpler mode

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

iii. a corporation established by or under a Central Act which is, under any law for the time being in force, exempt from income tax on its income, or iv. a Mutual fund specified under clause (23D) of section 10, where such sum is payable to it by way of interest or dividend in respect of any securities or shares

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

iii. a corporation established by or under a Central Act which is, under any law for the time being in force, exempt from income tax on its income, or iv. a Mutual fund specified under clause (23D) of section 10, where such sum is payable to it by way of interest or dividend in respect of any securities or shares

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

iii. Revenue received from non-PSC partners of Rs. 141,15,645 on account of supply of local material under mud engineering contracts, being in the nature of fees for technical services against the assessee offered it to be income covered u/s 44 BB of the act. iv. Revenue received from PSC partners of ₹ 748,383,154/– on account

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

iii. Revenue received from non-PSC partners of Rs. 141,15,645 on account of supply of local material under mud engineering contracts, being in the nature of fees for technical services against the assessee offered it to be income covered u/s 44 BB of the act. iv. Revenue received from PSC partners of ₹ 748,383,154/– on account

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

iii. Revenue received from non-PSC partners of Rs. 141,15,645 on account of supply of local material under mud engineering contracts, being in the nature of fees for technical services against the assessee offered it to be income covered u/s 44 BB of the act. iv. Revenue received from PSC partners of ₹ 748,383,154/– on account

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

iii. Revenue received from non-PSC partners of Rs. 141,15,645 on account of supply of local material under mud engineering contracts, being in the nature of fees for technical services against the assessee offered it to be income covered u/s 44 BB of the act. iv. Revenue received from PSC partners of ₹ 748,383,154/– on account

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

iii. Revenue received from non-PSC partners of Rs. 141,15,645 on account of supply of local material under mud engineering contracts, being in the nature of fees for technical services against the assessee offered it to be income covered u/s 44 BB of the act. iv. Revenue received from PSC partners of ₹ 748,383,154/– on account

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

iii. Revenue received from non-PSC partners of Rs. 141,15,645 on account of supply of local material under mud engineering contracts, being in the nature of fees for technical services against the assessee offered it to be income covered u/s 44 BB of the act. iv. Revenue received from PSC partners of ₹ 748,383,154/– on account