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

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

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

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

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

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

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

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

TDS is required to be made on the service tax component under Section 194J of the Act. 19. The question framed, is therefore, answered in the negative i.e. favour of the Assessee and against the Revenue.” 20. Further, the Hon’ble High Court of Uttarakhand in the case of DIT (International Taxation) Vs. M/s Schlumberger Asia Services

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

TDS is required to be made on the service tax component under Section 194J of the Act. 19. The question framed, is therefore, answered in the negative i.e. favour of the Assessee and against the Revenue.” 20. Further, the Hon’ble High Court of Uttarakhand in the case of DIT (International Taxation) Vs. M/s Schlumberger Asia Services

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

In the result, appeal of the Revenue is partly allowed

40(a)(ia) of the Act. 11. Heard the contentions of both the parties at length and perused the material available on record. The AO alleged that assessee made purchases of INR 53,94,983/- from one party namely, M/s. Tripura Enterprises and not deducted tax at source @ 0.1% as per section 194Q of the Act. It was the claim

THE JOINT COMMISSIONER OF INCOME TAX (TDS), DEHRADUN vs. THE DIRECTOR, HIGHER EDUCATION, NANITAL

In the result, all the Revenue’s appeals are dismissed

Bench: The Hon'Ble Itat. 3. That The Ld. Cit(Appeals), Haldwani Be Set Aside That Of The Ao Be Restored.”

40, 171/- without considering the fact that the quantum appeal in this case is still sub-judice before the Hon'ble ITAT. 3. That the Ld. CIT(Appeals), Haldwani be set aside that of the AO be restored.” 3. Facts of the case are that the assessee (deductor) was engaged with Uttarakhand State Infrastructure Development Corporation, UP Rajkiya Nirman Nigam

DCIT, CIRCLE- 2, INTL. TAXATION, DEHRADUN vs. SCHLUMBERGER ASIA SERVICES LTD., DEHRADUN

In the result, the appeal of the assessee for the Asst Year 2015-16 is partly allowed and that of the revenue is dismissed

Bench: Shri Saktijit Dey & Shri M. Balaganeshita No. 5223/Del/2018 (A. Y.: 2015-16) Schlumberger Asia Services Ltd, Vs. Dcit, 14Th Floor, Tower-C, Building Circle-2, No. 1, Dlf City, Phase-Ii, International Taxation, Gurgaon Dehradun (Appellant) (Respondent) Pan: Aadcs1107J

40,99,903/- u/s 244A of the Act at the Maximum Marginal Rate. With regard to the interest income on income tax refund, the assessee submitted during the course of assessment proceedings that it would be entitled for benefit as provided in section 115A(1)(a)(ii) of the Act . The ld. AO observed that the benefit of section 115A

SCHLUMBERGER ASIA SERVICES LTD.,DEHRADUN vs. DCIT, CIRCLE- 2, INTL. TAXATION, DEHRADUN

In the result, the appeal of the assessee for the Asst Year 2015-16 is partly allowed and that of the revenue is dismissed

Bench: Shri Saktijit Dey & Shri M. Balaganeshita No. 5223/Del/2018 (A. Y.: 2015-16) Schlumberger Asia Services Ltd, Vs. Dcit, 14Th Floor, Tower-C, Building Circle-2, No. 1, Dlf City, Phase-Ii, International Taxation, Gurgaon Dehradun (Appellant) (Respondent) Pan: Aadcs1107J

40,99,903/- u/s 244A of the Act at the Maximum Marginal Rate. With regard to the interest income on income tax refund, the assessee submitted during the course of assessment proceedings that it would be entitled for benefit as provided in section 115A(1)(a)(ii) of the Act . The ld. AO observed that the benefit of section 115A

DCIT, CIRCLE- 2, INTL. TAXATION, DEHRADUN vs. SCHLUMBERGER ASIA SERVICES LTD., DEHRADUN

In the result, the appeal of the assessee for the Asst Year 2015-16 is partly allowed and that of the revenue is dismissed

Bench: Shri Saktijit Dey & Shri M. Balaganeshita No. 5223/Del/2018 (A. Y.: 2015-16) Schlumberger Asia Services Ltd, Vs. Dcit, 14Th Floor, Tower-C, Building Circle-2, No. 1, Dlf City, Phase-Ii, International Taxation, Gurgaon Dehradun (Appellant) (Respondent) Pan: Aadcs1107J

40,99,903/- u/s 244A of the Act at the Maximum Marginal Rate. With regard to the interest income on income tax refund, the assessee submitted during the course of assessment proceedings that it would be entitled for benefit as provided in section 115A(1)(a)(ii) of the Act . The ld. AO observed that the benefit of section 115A

SCHLUMBERGER ASIA SERVICES LTD.,DEHRADUN vs. DCIT, CIRCLE- 2, INTL. TAXATION, DEHRADUN

In the result, the appeal of the assessee for the Asst Year 2015-16 is partly allowed and that of the revenue is dismissed

Bench: Shri Saktijit Dey & Shri M. Balaganeshita No. 5223/Del/2018 (A. Y.: 2015-16) Schlumberger Asia Services Ltd, Vs. Dcit, 14Th Floor, Tower-C, Building Circle-2, No. 1, Dlf City, Phase-Ii, International Taxation, Gurgaon Dehradun (Appellant) (Respondent) Pan: Aadcs1107J

40,99,903/- u/s 244A of the Act at the Maximum Marginal Rate. With regard to the interest income on income tax refund, the assessee submitted during the course of assessment proceedings that it would be entitled for benefit as provided in section 115A(1)(a)(ii) of the Act . The ld. AO observed that the benefit of section 115A