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

250(6) of the Income-tax Act, 1961 („Act‟), on the following grounds: Taxability of revenues from offshore supply of imported material 1. The learned CIT(A) has erred in holding that revenues received by the Appellant from offshore supply of imported material amounting to Rs 1,898,390,096 are taxable under section 44BB of the Act, as opposed

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

250(6) of the Income-tax Act, 1961 („Act‟), on the following grounds: Taxability of revenues from offshore supply of imported material 1. The learned CIT(A) has erred in holding that revenues received by the Appellant from offshore supply of imported material amounting to Rs 1,898,390,096 are taxable under section 44BB of the Act, as opposed

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

250(6) of the Income-tax Act, 1961 („Act‟), on the following grounds: Taxability of revenues from offshore supply of imported material 1. The learned CIT(A) has erred in holding that revenues received by the Appellant from offshore supply of imported material amounting to Rs 1,898,390,096 are taxable under section 44BB of the Act, as opposed

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

250(6) of the Income-tax Act, 1961 („Act‟), on the following grounds: Taxability of revenues from offshore supply of imported material 1. The learned CIT(A) has erred in holding that revenues received by the Appellant from offshore supply of imported material amounting to Rs 1,898,390,096 are taxable under section 44BB of the Act, as opposed

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

250(6) of the Income-tax Act, 1961 („Act‟), on the following grounds: Taxability of revenues from offshore supply of imported material 1. The learned CIT(A) has erred in holding that revenues received by the Appellant from offshore supply of imported material amounting to Rs 1,898,390,096 are taxable under section 44BB of the Act, as opposed

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

250(6) of the Income-tax Act, 1961 („Act‟), on the following grounds: Taxability of revenues from offshore supply of imported material 1. The learned CIT(A) has erred in holding that revenues received by the Appellant from offshore supply of imported material amounting to Rs 1,898,390,096 are taxable under section 44BB of the Act, as opposed

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

250(6) of the Income-tax Act, 1961 („Act‟), on the following grounds: Taxability of revenues from offshore supply of imported material 1. The learned CIT(A) has erred in holding that revenues received by the Appellant from offshore supply of imported material amounting to Rs 1,898,390,096 are taxable under section 44BB of the Act, as opposed

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

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

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

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

In the result, ground no.3 is allowed

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

250 of the Income Tax Act, 1961 (hereafter referred to as “the Act”) by Ld. CIT(A), Noida-2. In this case, the Revenue has filed the appeal basically challenging the action of Ld. CIT(A) in giving relief to the assessee on account of alleged deduction of tax at source u/s 194C of the Act instead of section 194J

KSHIPRA DHAWAN,SAHARANPUR vs. DCIT CEN CIR DDN, DEHRADUN

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

Bench: Shri Vimal Kumar & Shri Brajesh Kumar Singh

TDS o the interest amount of Rs.58,39,706/- paid to the said two NBFCs. According to the ld. CIT(A), as per second proviso to section 40(a)(ia) of the Act, the assessee could be prevented from the garb of this section if and only if the assessee is not deemed to be assessee in default under

KSHIPRA DHAWAN,SAHARANPUR vs. DCIT CEN CIR DDN, DEHRADUN

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

Bench: Shri Vimal Kumar & Shri Brajesh Kumar Singh

TDS o the interest amount of Rs.58,39,706/- paid to the said two NBFCs. According to the ld. CIT(A), as per second proviso to section 40(a)(ia) of the Act, the assessee could be prevented from the garb of this section if and only if the assessee is not deemed to be assessee in default under

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

In the result, the appeal is dismissed

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

250 of the Income Tax Act, 1961 (hereafter “the Act”), dated 16.09.2025, passed by Ld. CIT(A)- Noida-2. In this case, the Ld. AO is seen to have held the receipts on account of IP Charges received from Halliburton Offshore Services Inc. amounting to Rs.77,66,43,479/- to be in the nature of “Royalty

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

In the result, the appeal of the Revenue is dismissed

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

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

SOLAR TURBINES INTERNATIONAL COMPANY,BANGALORE vs. DCIT, CIRCLE- 2, INTERNATIONAL TAXATION, DEHRADUN

Appeal is dismissed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal(Through Video Conferencing) Assessment Year: 2014-15 M/S. Solar Turbines Vs. Dcit, International Company International Taxation, (Singapore Branch Of Solar Cirrcle-2, Turbines International Dehradun Company, Usa), M/S. Deloitte Haskins & Sells Deloitte Centre, Anchorage Ii, #100/2, Richmond Road, Bangalore -560025 Pan: Aajcs3585J (Appellant) (Respondent) Assessee By None Department By Sh. A.S. Rana, Sr. Dr Date Of Hearing 16.01.2026 Date Of Pronouncement 30.03.2026 Order

TDS [ITA 4052/Del./2015] The Appellant craves leave to add, alter, amend or delete any or all the grounds of appeal on or before the date of hearing.” 3. We next notice with the able assistance coming from the Revenue side that the assessee/appellant is aggrieved against the learned CIT(A)’s order dated 30th August, 2017 rejecting its section

DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE), DEHRADUN, DEHRADUN vs. STONEFIELD CONSTRUCTION, DEHRADUN, DEHRADUN

In the result, appeal of the Revenue is partly allowed

5. Aggrieved by the said order, Revenue is in appeal before the Tribunal by raising various Grounds of appeal. 6. Ground of appeal No.1 raised by the Revenue is with respect to deletion of disallowance of INR 33,24,865/- towards purchases made from Two parties namely, M/s. Raj Lubricants and M/s. Paras Enterprises

MB PETROLEUM SERVICES LLC,MUMBAI vs. DDIT, DEHRADUN

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

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

5,41,080/- being payment made to NOV Brandt Oilfield Services towards “rent for chemical handing equipment” without deduction of tax at source. Accordingly, the ld AO disallowed the same u/s 40(a)(i) of the Act in the draft assessment order which was upheld by the ld DRP. 13. The ld AO observed that the assessee has debited

MOHAN PAL,HALDWANI, NAINITAL vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, HALDWANI, ACIT-DCIT, CENTRAL CIRCLE, HALDWANI

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

250 of the Income Tax Act, 1961 [“the Act”] arising out of assessment orders, all dated 28.12.2019 passed u/s 143(3) r.w.s. 153C of the Act pertaining to Assessment Year 2013-14 to 2015-16 respectively. 2. Ld.AR for the assessee filed an application for admission of additional grounds of appeal and contended containing that these additional grounds of appeal

MOHAN PAL,HALDWANI, NAINITAL vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, HALDWANI, ACIT - DCIT, CENTRAL CIRCLE, HALDWANI

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

250 of the Income Tax Act, 1961 [“the Act”] arising out of assessment orders, all dated 28.12.2019 passed u/s 143(3) r.w.s. 153C of the Act pertaining to Assessment Year 2013-14 to 2015-16 respectively. 2. Ld.AR for the assessee filed an application for admission of additional grounds of appeal and contended containing that these additional grounds of appeal