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42 results for “TDS”+ Section 25clear

Sorted by relevance

Mumbai2,927Delhi2,863Bangalore1,561Chennai1,050Kolkata669Ahmedabad514Hyderabad440Pune404Indore290Jaipur277Cochin270Chandigarh233Raipur225Karnataka195Surat121Nagpur106Rajkot96Cuttack92Visakhapatnam81Lucknow77Amritsar46Jodhpur44Dehradun42Ranchi39Guwahati38Agra30Allahabad29Kerala26Telangana26Panaji25Patna22SC12Jabalpur11Varanasi10Calcutta7Rajasthan5Uttarakhand2Orissa2Bombay1Himachal Pradesh1

Key Topics

Section 44B105Section 44D28Section 194A23Addition to Income18Section 143(3)17Section 915Section 271C13TDS12Deduction11Section 44A

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

25, of the paper book. 3) Section 194A-relates to the provisions for deducting tax at source on the payment; of interest other than 'interest on securities'. Attention is invited to the provisions of section 194A(3)(iii) (f) which interalia provides as under:- "The provisions of sub-section (1) to section 194A shall not apply - to such income credited

Showing 1–20 of 42 · Page 1 of 3

10
Section 12A8
Disallowance8

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

25, of the paper book. 3) Section 194A-relates to the provisions for deducting tax at source on the payment; of interest other than 'interest on securities'. Attention is invited to the provisions of section 194A(3)(iii) (f) which interalia provides as under:- "The provisions of sub-section (1) to section 194A shall not apply - to such income credited

SMITH INTERNATIONAL INC.,MUMBAI vs. ADIT, DEHRADUN

In the result, both the appeals of the assessee are allowed and both the appeals of the Revenue are dismissed

ITA 3824/DEL/2014[2010-11]Status: DisposedITAT Dehradun10 Nov 2021AY 2010-11

Bench: Sh. Amit Shukladr. B. R. R. Kumarita No. 4561/Del/2013 : Asstt. Year : 2009-10 Ita No. 3824/Del/2014 : Asstt. Year : 2010-11 Smith International Inc., Vs Adit, 806-807, Powai Plaza, Central International Taxation, Avenue, Hiranandani Garden, Dehradun Powai, Mumbai-400076 (Appellant) (Respondent) Pan No. Aahcs3148R

For Appellant: Sh. Salil Kapoor, AdvFor Respondent: Sh. T. S. Mapwal, Sr. DR
Section 115ASection 143Section 293ASection 42Section 44ASection 44BSection 44D

25. Key observations by the Division Bench in the said ruling are as under: • Section 44BB specifically states that “any amount paid or payable (in or outside India) or any amounts received or deemed to be received in India on account of the provision of services and facilities”. Accordingly, chargeability under Section 44BB is restricted only to the amounts received

ADIT, DEHRADUN vs. M/S. SMITH INTERNATIONAL INC., DEHRADUN

In the result, both the appeals of the assessee are allowed and both the appeals of the Revenue are dismissed

ITA 4651/DEL/2013[2009-10]Status: DisposedITAT Dehradun10 Nov 2021AY 2009-10

Bench: Sh. Amit Shukladr. B. R. R. Kumarita No. 4561/Del/2013 : Asstt. Year : 2009-10 Ita No. 3824/Del/2014 : Asstt. Year : 2010-11 Smith International Inc., Vs Adit, 806-807, Powai Plaza, Central International Taxation, Avenue, Hiranandani Garden, Dehradun Powai, Mumbai-400076 (Appellant) (Respondent) Pan No. Aahcs3148R

For Appellant: Sh. Salil Kapoor, AdvFor Respondent: Sh. T. S. Mapwal, Sr. DR
Section 115ASection 143Section 293ASection 42Section 44ASection 44BSection 44D

25. Key observations by the Division Bench in the said ruling are as under: • Section 44BB specifically states that “any amount paid or payable (in or outside India) or any amounts received or deemed to be received in India on account of the provision of services and facilities”. Accordingly, chargeability under Section 44BB is restricted only to the amounts received

DDIT, DEHRADUN vs. M/S. SMITH INTERNATIONAL INC., DEHRADUN

In the result, both the appeals of the assessee are allowed and both the appeals of the Revenue are dismissed

ITA 3909/DEL/2014[2010-11]Status: DisposedITAT Dehradun10 Nov 2021AY 2010-11

Bench: Sh. Amit Shukladr. B. R. R. Kumarita No. 4561/Del/2013 : Asstt. Year : 2009-10 Ita No. 3824/Del/2014 : Asstt. Year : 2010-11 Smith International Inc., Vs Adit, 806-807, Powai Plaza, Central International Taxation, Avenue, Hiranandani Garden, Dehradun Powai, Mumbai-400076 (Appellant) (Respondent) Pan No. Aahcs3148R

For Appellant: Sh. Salil Kapoor, AdvFor Respondent: Sh. T. S. Mapwal, Sr. DR
Section 115ASection 143Section 293ASection 42Section 44ASection 44BSection 44D

25. Key observations by the Division Bench in the said ruling are as under: • Section 44BB specifically states that “any amount paid or payable (in or outside India) or any amounts received or deemed to be received in India on account of the provision of services and facilities”. Accordingly, chargeability under Section 44BB is restricted only to the amounts received

SMITH INTERNATIONAL INC.,MUMBAI vs. ADIT, DEHRADUN

In the result, both the appeals of the assessee are allowed and both the appeals of the Revenue are dismissed

ITA 4561/DEL/2013[2009-10]Status: DisposedITAT Dehradun10 Nov 2021AY 2009-10

Bench: Sh. Amit Shukladr. B. R. R. Kumarita No. 4561/Del/2013 : Asstt. Year : 2009-10 Ita No. 3824/Del/2014 : Asstt. Year : 2010-11 Smith International Inc., Vs Adit, 806-807, Powai Plaza, Central International Taxation, Avenue, Hiranandani Garden, Dehradun Powai, Mumbai-400076 (Appellant) (Respondent) Pan No. Aahcs3148R

For Appellant: Sh. Salil Kapoor, AdvFor Respondent: Sh. T. S. Mapwal, Sr. DR
Section 115ASection 143Section 293ASection 42Section 44ASection 44BSection 44D

25. Key observations by the Division Bench in the said ruling are as under: • Section 44BB specifically states that “any amount paid or payable (in or outside India) or any amounts received or deemed to be received in India on account of the provision of services and facilities”. Accordingly, chargeability under Section 44BB is restricted only to the amounts received

ACIT, CIRCLE- 2, DEHRADUN vs. RAJESH BALLABH, DEHRADUN

In the result appeal of the Revenue is dismissed

ITA 44/DEL/2018[2014-15]Status: DisposedITAT Dehradun19 Jan 2022AY 2014-15

Bench: Shri R.K.Panda & Shri K.Narasimha Chary

Section 194CSection 201Section 40Section 44A

TDS under section 194C, whereas w.e.f. 1/6/2015 the transport suppliers shall also furnish a declaration that he owns less than 10 carriages at any time during the Page 4 of 8 financial year relevant to the assessment year. Further the provision as applicable up to 31/5/2015 does not bar the exemption to small or large transport operators and is only

ACIT, CIRCLE- 2, INTERNATIONAL TAXATION, DEHRADUN vs. SOLAR TURBINES INTERNATIONAL CO., BENGALURU

In the result, the appeal of the Revenue is dismissed

ITA 441/DEL/2018[2013-14]Status: DisposedITAT Dehradun29 Apr 2022AY 2013-14

Bench: Dr. B.R.R. Kumar & Sh. Yogesh Kumar U.S.Assessment Year: 2014-15 Solar Turbines International Vs Dcit, Company (Singapore Branch Of Circle-2, Solar Turbines International International Taxation, Company, Usa), Dehradun. 14 Tractor Road, Singapore, C/O Delloitte Haskins & Sells Llp, Deloitte Centre Anchorage- Ii, Richmond Road, Bangalore. (Appellant) (Respondent) Pan No. Aajcs3585J Assessment Year: 2014-15

For Appellant: NoneFor Respondent: Shri T.S. Mapwal, Sr.DR
Section 2(43)Section 40Section 43BSection 90(2)

TDS [ITA 4052/Del/2015. 2. The assessee has raised the issue of levy of surcharge and education cess. This issue is no longer res integra as amended involved to the clarification has been brought in the memorandum explaining the provisions in the Finance Bill, 2022 wherein it was clarified that the deduction for taxes paid as cess cannot be allowed

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

25 November 2011. Assessee is aggrieved with that order. 42. The assessee has raised the following grounds of appeal in ITA No. 462/Del/2012 for the Assessment Year 2008-09:- “1. The order passed by The Asst. Director of Income Tax, International Taxation , Dehradun (AO) under section 143(3) read with section 144C and 154 of the Income

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

25 November 2011. Assessee is aggrieved with that order. 42. The assessee has raised the following grounds of appeal in ITA No. 462/Del/2012 for the Assessment Year 2008-09:- “1. The order passed by The Asst. Director of Income Tax, International Taxation , Dehradun (AO) under section 143(3) read with section 144C and 154 of the Income

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

25 November 2011. Assessee is aggrieved with that order. 42. The assessee has raised the following grounds of appeal in ITA No. 462/Del/2012 for the Assessment Year 2008-09:- “1. The order passed by The Asst. Director of Income Tax, International Taxation , Dehradun (AO) under section 143(3) read with section 144C and 154 of the Income

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

25 November 2011. Assessee is aggrieved with that order. 42. The assessee has raised the following grounds of appeal in ITA No. 462/Del/2012 for the Assessment Year 2008-09:- “1. The order passed by The Asst. Director of Income Tax, International Taxation , Dehradun (AO) under section 143(3) read with section 144C and 154 of the Income

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

25 November 2011. Assessee is aggrieved with that order. 42. The assessee has raised the following grounds of appeal in ITA No. 462/Del/2012 for the Assessment Year 2008-09:- “1. The order passed by The Asst. Director of Income Tax, International Taxation , Dehradun (AO) under section 143(3) read with section 144C and 154 of the 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

25 November 2011. Assessee is aggrieved with that order. 42. The assessee has raised the following grounds of appeal in ITA No. 462/Del/2012 for the Assessment Year 2008-09:- “1. The order passed by The Asst. Director of Income Tax, International Taxation , Dehradun (AO) under section 143(3) read with section 144C and 154 of the Income

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

25 November 2011. Assessee is aggrieved with that order. 42. The assessee has raised the following grounds of appeal in ITA No. 462/Del/2012 for the Assessment Year 2008-09:- “1. The order passed by The Asst. Director of Income Tax, International Taxation , Dehradun (AO) under section 143(3) read with section 144C and 154 of the Income

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

25% as against said income offered to tax under section 44BB of the Act in the ROI; 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

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

TDS is required to be made on the service tax component under Section 194J of the Act. 21. The question framed, is therefore, answered in the negative i.e. favour of the Assessee and against the Revenue.” 11 ITA No.6174, 6175.Del.2017 Transocean Offshore 22. Further Hon’ble High Court of Uttarakhand in the case of DIT International Taxation

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

TDS is required to be made on the service tax component under Section 194J of the Act. 21. The question framed, is therefore, answered in the negative i.e. favour of the Assessee and against the Revenue.” 11 ITA No.6174, 6175.Del.2017 Transocean Offshore 22. Further Hon’ble High Court of Uttarakhand in the case of DIT International Taxation

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

TDS is required to be made on the service tax component under Section 194J of the Act. 21. The question framed, is therefore, answered in the negative i.e. favour of the Assessee and against the Revenue.” 22. Further Hon’ble High Court of Uttarakhand in the case of DIT International Taxation Vs M/s Schlumberger Asia Services

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

25 .11.2021 O R D E R PER B.R.R.KUMAR, ACCOUNTANT MEMBER : This appeal has been filed by the revenue against the order of the ld. CIT(A)-2, Noida, dated 27.07.2017. 2. The only issue involved in this case is that whether service tax is includable in the gross revenue for computing profits under presumptive provisions of section 44BB