DCIT (INTERNATIONAL TAXATION), DEHRADUN vs. M/S. SAMSUNG HEAVY INDUSTRIES CO. LTD., GURGAON

In the result, appeal of the assessee in ITA No

227 Circle-2, Dehradun Beon-Gil Bundang-Gu, Seongnam-SI, Gyeonggi-Do (13486) South Korea PAN-AAJCS 7859K (Appellant) (Respondent) Assessee By Sh. Ravi Sharma, Advocate and Smt. Shruti Khima, AR Department by Sh. Mayank Kumar, Addl. CIT- DR (Intt. Date of Hearing 12/12/2023 Date of Pronouncement 22/12/2023 ORDER PER M.BALAGANESH, AM: 1. These are the appeals filed

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

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

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

227 (Delhi) and the appeal of the assessee was dismissed. He submitted that though the appeal was dismissed holding that there is an order which is erroneous and prejudicial to the interest of the revenue, however, observations at para number 5 of that order clearly clinches the issue against the assessee wherein it has been held that both the services

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

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

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

227 (Delhi) and the appeal of the assessee was dismissed. He submitted that though the appeal was dismissed holding that there is an order which is erroneous and prejudicial to the interest of the revenue, however, observations at para number 5 of that order clearly clinches the issue against the assessee wherein it has been held that both the services

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

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

227 (Delhi) and the appeal of the assessee was dismissed. He submitted that though the appeal was dismissed holding that there is an order which is erroneous and prejudicial to the interest of the revenue, however, observations at para number 5 of that order clearly clinches the issue against the assessee wherein it has been held that both the services

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

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

227 (Delhi) and the appeal of the assessee was dismissed. He submitted that though the appeal was dismissed holding that there is an order which is erroneous and prejudicial to the interest of the revenue, however, observations at para number 5 of that order clearly clinches the issue against the assessee wherein it has been held that both the services

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

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

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

227 (Delhi) and the appeal of the assessee was dismissed. He submitted that though the appeal was dismissed holding that there is an order which is erroneous and prejudicial to the interest of the revenue, however, observations at para number 5 of that order clearly clinches the issue against the assessee wherein it has been held that both the services

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

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

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

227 (Delhi) and the appeal of the assessee was dismissed. He submitted that though the appeal was dismissed holding that there is an order which is erroneous and prejudicial to the interest of the revenue, however, observations at para number 5 of that order clearly clinches the issue against the assessee wherein it has been held that both the services

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

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

227 (Delhi) and the appeal of the assessee was dismissed. He submitted that though the appeal was dismissed holding that there is an order which is erroneous and prejudicial to the interest of the revenue, however, observations at para number 5 of that order clearly clinches the issue against the assessee wherein it has been held that both the services