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

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

TDS returns under Section 200A of the Act, clause (c) to Sub-Section(1) to Section 200A was introduced with effect from 01.07.2012. Therefore, the 5

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

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

TDS returns under Section 200A of the Act, clause (c) to Sub-Section(1) to Section 200A was introduced with effect from 01.07.2012. Therefore, the 5

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

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

TDS returns under Section 200A of the Act, clause (c) to Sub-Section(1) to Section 200A was introduced with effect from 01.07.2012. Therefore, the 5

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

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

TDS returns under Section 200A of the Act, clause (c) to Sub-Section(1) to Section 200A was introduced with effect from 01.07.2012. Therefore, the 5

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

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

TDS returns under Section 200A of the Act, clause (c) to Sub-Section(1) to Section 200A was introduced with effect from 01.07.2012. Therefore, the 5

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

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

TDS returns under Section 200A of the Act, clause (c) to Sub-Section(1) to Section 200A was introduced with effect from 01.07.2012. Therefore, the 5

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

5. Grounds 2,3 and 4 need to be adjudicated jointly since they are interconnected. It may be reiterated that on identical issues, decision has been rendered in favour of the Appellant on the basis of the CGG Veritas case (supra). However, after the CGG Veritas case (supra), the decision in the case of Ohm Ltd. (supra) has put things

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

5 raised by the assessee for the Asst Year 2015-16 regarding the taxability of interest on income tax refund at Maximum Marginal Rate or as per section 115A of the Act. 10.1. We have heard the rival submissions and perused the materials available on record. The assessee also offered interest income on Income Tax Refund under the head ‘income

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

5 raised by the assessee for the Asst Year 2015-16 regarding the taxability of interest on income tax refund at Maximum Marginal Rate or as per section 115A of the Act. 10.1. We have heard the rival submissions and perused the materials available on record. The assessee also offered interest income on Income Tax Refund under the head ‘income

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

5 raised by the assessee for the Asst Year 2015-16 regarding the taxability of interest on income tax refund at Maximum Marginal Rate or as per section 115A of the Act. 10.1. We have heard the rival submissions and perused the materials available on record. The assessee also offered interest income on Income Tax Refund under the head ‘income

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

5 raised by the assessee for the Asst Year 2015-16 regarding the taxability of interest on income tax refund at Maximum Marginal Rate or as per section 115A of the Act. 10.1. We have heard the rival submissions and perused the materials available on record. The assessee also offered interest income on Income Tax Refund under the head ‘income

DR. VIRENDRA SWAROOP EDUCATIONAL FOUNDATION,KANPUR vs. ACIT, CENTRAL CIRCLE, DEHRADUN, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2023-24] Dr. Virendra Swaroop Vs Acit Educational Foundation Central Circle 15/96, Civil Lines, Kanpur Dehradun Uttar Pradesh-208001 Pan-Aaajd0224D Appellant Respondent Assessee By Shri Salil Kapoor, Adv. Shri Rajiv Sahni, Ca Shri Sumit Lal Chandanim, Adv. Shri Shivam Yadav, Adv. & Ms. Ananya Kapoor, Adv. Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 11.12.2025 Date Of Pronouncement 16.01.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 16.09.2025 By Ld. Pr. Commissioner Of Income Tax (Central), Kanpur [“Pcit”] Passed U/S 12(Ab)(4)(Ii) Of The Income Tax Act, 1961[“The Act”] Cancelling The Registration Granted U/S 12A Of The Act From Assessment Year 2023-24 & Onwards.

5. That the impugned order passed by the PCIT under Section 12AB(4) (ii) of the Act is without jurisdiction in the absence of a valid order under Section 127 of the Act, and is therefore null and void. 6. Without prejudice, the order under Section 127 of the Act does not apply to the jurisdiction being held

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

TDS to the extent of Rs 12,890,927. Levy of interest 7. The learned CIT(A) has erred in law and in fact, by upholding levy of interest under section 234A of the Act, amounting to Rs.4,125,414.” 63. We first come to the appeal of the assessee. Per ground number 1 – 4, the assessee has challenged

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

TDS to the extent of Rs 12,890,927. Levy of interest 7. The learned CIT(A) has erred in law and in fact, by upholding levy of interest under section 234A of the Act, amounting to Rs.4,125,414.” 63. We first come to the appeal of the assessee. Per ground number 1 – 4, the assessee has challenged

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

TDS to the extent of Rs 12,890,927. Levy of interest 7. The learned CIT(A) has erred in law and in fact, by upholding levy of interest under section 234A of the Act, amounting to Rs.4,125,414.” 63. We first come to the appeal of the assessee. Per ground number 1 – 4, the assessee has challenged

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

TDS to the extent of Rs 12,890,927. Levy of interest 7. The learned CIT(A) has erred in law and in fact, by upholding levy of interest under section 234A of the Act, amounting to Rs.4,125,414.” 63. We first come to the appeal of the assessee. Per ground number 1 – 4, the assessee has challenged

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

TDS to the extent of Rs 12,890,927. Levy of interest 7. The learned CIT(A) has erred in law and in fact, by upholding levy of interest under section 234A of the Act, amounting to Rs.4,125,414.” 63. We first come to the appeal of the assessee. Per ground number 1 – 4, the assessee has challenged

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

TDS to the extent of Rs 12,890,927. Levy of interest 7. The learned CIT(A) has erred in law and in fact, by upholding levy of interest under section 234A of the Act, amounting to Rs.4,125,414.” 63. We first come to the appeal of the assessee. Per ground number 1 – 4, the assessee has challenged