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

3. The learned CIT(A) has erred in rejecting the Appellant‟s claim, wherein the Appellant had offered 2% of the revenues from offshore supply of imported materials from PSC and Non-PSC partners to tax following the assessment order for AY 2006-07, in order to avoid litigation and to buy peace of mind. 4. The learned

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

3. The learned CIT(A) has erred in rejecting the Appellant‟s claim, wherein the Appellant had offered 2% of the revenues from offshore supply of imported materials from PSC and Non-PSC partners to tax following the assessment order for AY 2006-07, in order to avoid litigation and to buy peace of mind. 4. The learned

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

3. The learned CIT(A) has erred in rejecting the Appellant‟s claim, wherein the Appellant had offered 2% of the revenues from offshore supply of imported materials from PSC and Non-PSC partners to tax following the assessment order for AY 2006-07, in order to avoid litigation and to buy peace of mind. 4. The learned

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

3. The learned CIT(A) has erred in rejecting the Appellant‟s claim, wherein the Appellant had offered 2% of the revenues from offshore supply of imported materials from PSC and Non-PSC partners to tax following the assessment order for AY 2006-07, in order to avoid litigation and to buy peace of mind. 4. The learned

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

3. The learned CIT(A) has erred in rejecting the Appellant‟s claim, wherein the Appellant had offered 2% of the revenues from offshore supply of imported materials from PSC and Non-PSC partners to tax following the assessment order for AY 2006-07, in order to avoid litigation and to buy peace of mind. 4. The learned

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

3. The learned CIT(A) has erred in rejecting the Appellant‟s claim, wherein the Appellant had offered 2% of the revenues from offshore supply of imported materials from PSC and Non-PSC partners to tax following the assessment order for AY 2006-07, in order to avoid litigation and to buy peace of mind. 4. The learned

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

3. The learned CIT(A) has erred in rejecting the Appellant‟s claim, wherein the Appellant had offered 2% of the revenues from offshore supply of imported materials from PSC and Non-PSC partners to tax following the assessment order for AY 2006-07, in order to avoid litigation and to buy peace of mind. 4. The learned

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

2. The activities of the appellant are NOT “general in nature” and are directly in connection with the oil & gas E&P 2.1. Based on the scope of work awarded to the appellant, the following activities were performed by the appellant:  Cementing Services  Drill stem testing services;  Wireline Logging:  Measurement-while-logging (MWD)  Logging-while-drilling (LWD)  Coring Services  Electro

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

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

3. The Revenue vehemently argues during the course of hearing that both the learned lower authorities have rightly levied the late filing fee herein forming subject matter of adjudication in all these eight appeals on account of the fact that the assessee/deductor had committed the corresponding default in belated filing/upholding of the prescribed statement under section 200 read with section

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

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

3. The Revenue vehemently argues during the course of hearing that both the learned lower authorities have rightly levied the late filing fee herein forming subject matter of adjudication in all these eight appeals on account of the fact that the assessee/deductor had committed the corresponding default in belated filing/upholding of the prescribed statement under section 200 read with section

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

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

3. The Revenue vehemently argues during the course of hearing that both the learned lower authorities have rightly levied the late filing fee herein forming subject matter of adjudication in all these eight appeals on account of the fact that the assessee/deductor had committed the corresponding default in belated filing/upholding of the prescribed statement under section 200 read with section

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

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

3. The Revenue vehemently argues during the course of hearing that both the learned lower authorities have rightly levied the late filing fee herein forming subject matter of adjudication in all these eight appeals on account of the fact that the assessee/deductor had committed the corresponding default in belated filing/upholding of the prescribed statement under section 200 read with section

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

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

3. The Revenue vehemently argues during the course of hearing that both the learned lower authorities have rightly levied the late filing fee herein forming subject matter of adjudication in all these eight appeals on account of the fact that the assessee/deductor had committed the corresponding default in belated filing/upholding of the prescribed statement under section 200 read with section

CHIEF EDUCATION OFFICER,DEHRADUN vs. CIT (AI, DEHRADUN

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

3. The Revenue vehemently argues during the course of hearing that both the learned lower authorities have rightly levied the late filing fee herein forming subject matter of adjudication in all these eight appeals on account of the fact that the assessee/deductor had committed the corresponding default in belated filing/upholding of the prescribed statement under section 200 read with section

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

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

3. The Revenue vehemently argues during the course of hearing that both the learned lower authorities have rightly levied the late filing fee herein forming subject matter of adjudication in all these eight appeals on account of the fact that the assessee/deductor had committed the corresponding default in belated filing/upholding of the prescribed statement under section 200 read with section

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

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

3. The Revenue vehemently argues during the course of hearing that both the learned lower authorities have rightly levied the late filing fee herein forming subject matter of adjudication in all these eight appeals on account of the fact that the assessee/deductor had committed the corresponding default in belated filing/upholding of the prescribed statement under section 200 read with section

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

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

3) brokerage, commission, interest etc. did not form part of the business profits because they did not involve any element of export turnover. It was observed: “just as commission received by an assessee is relatable to exports and yet it cannot form part of ‘turnover’, excise duty and sales-tax also cannot form part of the ‘turnover’.” The object

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

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

3) brokerage, commission, interest etc. did not form part of the business profits because they did not involve any element of export turnover. It was observed: “just as commission received by an assessee is relatable to exports and yet it cannot form part of ‘turnover’, excise duty and sales-tax also cannot form part of the ‘turnover’.” The object

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

In the result, appeal of the revenue is dismissed

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

3) brokerage, commission, interest etc. did not form part of the business profits because they did not involve any element of export turnover. It was observed: “just as commission received by an assessee is relatable to exports and yet it cannot form part of ‘turnover’, excise duty and sales-tax also cannot form part of the ‘turnover’.” The object