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

RAJIV KUMAR TIWARI,SAHARANPUR vs. DCIT-ACIT- 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 Singhassessment Year: 2018-19 Rajiv Kumar Tiwari, Acit, Central Circle, A-7, Awas Vikas, Dehradun, Income Tax Office, 52/1, Delhi Road, Vs Rajpur Road, Dehradun Saharanpur, Uttarakhand-248001 Uttar Pradesh-247001 Pan-Adfpt9463L Appellant Respondent

TDS on the interest paid to the said four NBFCs. According to the ld. CIT(A), as per second proviso to section 40

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

In the result, appeal of the assessee in ITA No

TDS on pre- engineering and survey was belatedly made, therefore, he excluded the expenses of Rs. 35,18,206/- on the ground of application of section 40

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

In the result, appeal of the assessee in ITA No

TDS on pre- engineering and survey was belatedly made, therefore, he excluded the expenses of Rs. 35,18,206/- on the ground of application of section 40

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

TDS was deducted at the rate of 2%. The appellant has further submitted that the AO failed to appreciate that section 40

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

In the result appeal of the Revenue is dismissed

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

section 40(a)(ia) of the Act, a sum of Rs. 3,65,32,392/-has to be added to the income of the assessee. 4. Learned Assessing Officer further observed that there are vehicle running expenses to the tune of Rs. 72,18,722/- and since the assessee failed to produce any supporting evidences/bills and vouchers in support

GULF PIPING COMPANY WLL,ABU DHABI vs. DY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

section 40(a)(i), Id. CIT(A) observed that first of all, expenses claimed in computing the income chargeable under the head 'profits and gains of business or profession' towards royalty, fee for technical services or other sum chargeable under the Act which is payable outside India or in India to a non- resident on which TDS

GULF PIPING COMPANY WLL,UNITED ARAB EMIRATES vs. DY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

section 40(a)(i), Id. CIT(A) observed that first of all, expenses claimed in computing the income chargeable under the head 'profits and gains of business or profession' towards royalty, fee for technical services or other sum chargeable under the Act which is payable outside India or in India to a non- resident on which TDS

GULF PIPING COMPANY WLL,UNITED ARAB EMIRATES vs. DY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

section 40(a)(i), Id. CIT(A) observed that first of all, expenses claimed in computing the income chargeable under the head 'profits and gains of business or profession' towards royalty, fee for technical services or other sum chargeable under the Act which is payable outside India or in India to a non- resident on which TDS

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

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

TDS. 13. That the explanations, submissions and evidences filed by the assessee have not been considered judiciously and examined and interpreted legally. 14. That the additions are based on surmises and conjectures and guesswork and cannot be justified by the material on record. 15. That in any case the additions sustained are highly excessive and cannot be justified

M.B. PETROLEUM SERVICES LLC,NEW DELHI vs. DCIT (INTERNATIONAL TAXATION), DEHRADUN

In the result, the appeal of the assessee is allowed

TDS. 7. Without prejudice to above and in law and circumstances of the case, the Ld. AO has erred in denying the claim of depreciation and amortization of Rs. 49,75,184/-. 8. Without prejudice to above and in law and circumstances of the case, the Ld. AO erred in disallowing expense of Rs.11,660/- on the ground that they

BG EXPLORATION & PRODUCTION INDIA LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX DDIT/ADIT (INTERNATIONAL TAXATION ) CIRCLE-1, DEHRADUN

In the result, the appeal of the assessee is partly allowed

Bench: Shri R.K. Panda & Shri V.P. Raoassessment Years: 2016-17

40(a)(ii) of the Act. He has also relied upon the decision of Hon’ble Bombay High Court in the case of Sesa Goa Ltd. v. JCIT (2020) 117 taxmann.com 96 (Bom) on this issue. Placing reliance on the precedents, as laid down by Hon’ble Rajasthan High court and Hon’ble Bombay High Court, he has submitted that

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

40. In the result, appeal of the assessee for assessment year 2007 – 08 in ITA number 5583/Del/2013 is dismissed. Assessment year 2008 – 09 41. ITA number 462/Del/2012 is filed by the assessee against the order passed by the learned Assistant Director Of Income Tax, International Taxation, Dehradun (the learned AO) passed on 25 November 2011 u/s 143 (3) read with

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

40. In the result, appeal of the assessee for assessment year 2007 – 08 in ITA number 5583/Del/2013 is dismissed. Assessment year 2008 – 09 41. ITA number 462/Del/2012 is filed by the assessee against the order passed by the learned Assistant Director Of Income Tax, International Taxation, Dehradun (the learned AO) passed on 25 November 2011 u/s 143 (3) read with

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

40. In the result, appeal of the assessee for assessment year 2007 – 08 in ITA number 5583/Del/2013 is dismissed. Assessment year 2008 – 09 41. ITA number 462/Del/2012 is filed by the assessee against the order passed by the learned Assistant Director Of Income Tax, International Taxation, Dehradun (the learned AO) passed on 25 November 2011 u/s 143 (3) read with

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

40. In the result, appeal of the assessee for assessment year 2007 – 08 in ITA number 5583/Del/2013 is dismissed. Assessment year 2008 – 09 41. ITA number 462/Del/2012 is filed by the assessee against the order passed by the learned Assistant Director Of Income Tax, International Taxation, Dehradun (the learned AO) passed on 25 November 2011 u/s 143 (3) read with

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

40. In the result, appeal of the assessee for assessment year 2007 – 08 in ITA number 5583/Del/2013 is dismissed. Assessment year 2008 – 09 41. ITA number 462/Del/2012 is filed by the assessee against the order passed by the learned Assistant Director Of Income Tax, International Taxation, Dehradun (the learned AO) passed on 25 November 2011 u/s 143 (3) read with