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

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

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

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 Date of Hearing 18.04.2022 Date of Pronouncement 05.05.2022 PER R.K. PANDA, AM, These are cross appeals. The first one is filed by the assessee and the second one filed

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

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

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.

TDS and the same is adjusted towards the payment for said purpose and the fact that other party had noted the same as unsecured loan in his books of accounts is immaterial. 12. That the PCIT, had erred on facts and in law, in holding that there is cash transaction and adjustment towards the payment of car, whereas, there

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

c) Rs. 2,53,99,401/- ( for services contract under well test division of ONGC Contract). 8. The ld AO concluded that the services performed under both the contracts are in the nature of Fees For Technical Services (FTS) as defined u/s 9(1)(vii) of the Act as according to him, the services rendered are technical in nature

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 filed by the assessee is partly allowed for statistical purposes

c. RBI approval for opening branch office was restricted to carryout activities mentioned in the annexure to the approval. The branch office has not undertaken any of the activities mentioned in the annexure other than the JV. Hence the claim of the assessee that it has been undertaking activities other than the ones related to the JV does not appear

BLOCK DEVELOPMENT OFFICER,BIJNOR vs. THE COMMISSIONER OF INCOME TAX (A), , HALDWANI

In the result, appeals are allowed for statistical purposes

Bench: Shri Saktijit Dey & Dr. B.R.R. Kumarassessment Year: 2013-14 With Assessment Year: 2013-14 With Assessment Year: 2014-15 With Assessment Year: 2015-16 With Assessment Year: 2016-17 With Assessment Year: 2014-15 With Assessment Year: 2016-17 With Assessment Year: 2015-16 With Assessment Year: 2017-18 With Assessment Year: 2018-19 With Assessment Year: 2019-20

c) was introduced to section 200A(1) with effect from 01.06.2015 empowering the authority concerned to levy fee under section 234E of the Act while processing TDS statement. Thus, under section 200A of the Act, the authority concerned is empowered to levy fee under section 234E of the Act prospectively with effect from

BLOCK DEVELOPMENT OFFICER,BIJNOR vs. THE COMMISSIONER OF INCOME TAX (A), HALDEANI

In the result, appeals are allowed for statistical purposes

Bench: Shri Saktijit Dey & Dr. B.R.R. Kumarassessment Year: 2013-14 With Assessment Year: 2013-14 With Assessment Year: 2014-15 With Assessment Year: 2015-16 With Assessment Year: 2016-17 With Assessment Year: 2014-15 With Assessment Year: 2016-17 With Assessment Year: 2015-16 With Assessment Year: 2017-18 With Assessment Year: 2018-19 With Assessment Year: 2019-20

c) was introduced to section 200A(1) with effect from 01.06.2015 empowering the authority concerned to levy fee under section 234E of the Act while processing TDS statement. Thus, under section 200A of the Act, the authority concerned is empowered to levy fee under section 234E of the Act prospectively with effect from

BLOCK DEVELOPMENT OFFICER,BIJNOR vs. THE COMMISSIONER OF INCOME TAX(A), HALDWANI

In the result, appeals are allowed for statistical purposes

Bench: Shri Saktijit Dey & Dr. B.R.R. Kumarassessment Year: 2013-14 With Assessment Year: 2013-14 With Assessment Year: 2014-15 With Assessment Year: 2015-16 With Assessment Year: 2016-17 With Assessment Year: 2014-15 With Assessment Year: 2016-17 With Assessment Year: 2015-16 With Assessment Year: 2017-18 With Assessment Year: 2018-19 With Assessment Year: 2019-20

c) was introduced to section 200A(1) with effect from 01.06.2015 empowering the authority concerned to levy fee under section 234E of the Act while processing TDS statement. Thus, under section 200A of the Act, the authority concerned is empowered to levy fee under section 234E of the Act prospectively with effect from

BLOCK DEVELOPMENT OFFICER,BIJNOR vs. THE COMMISSIONER OF INCOME TAX (A), HALDWANI

In the result, appeals are allowed for statistical purposes

Bench: Shri Saktijit Dey & Dr. B.R.R. Kumarassessment Year: 2013-14 With Assessment Year: 2013-14 With Assessment Year: 2014-15 With Assessment Year: 2015-16 With Assessment Year: 2016-17 With Assessment Year: 2014-15 With Assessment Year: 2016-17 With Assessment Year: 2015-16 With Assessment Year: 2017-18 With Assessment Year: 2018-19 With Assessment Year: 2019-20

c) was introduced to section 200A(1) with effect from 01.06.2015 empowering the authority concerned to levy fee under section 234E of the Act while processing TDS statement. Thus, under section 200A of the Act, the authority concerned is empowered to levy fee under section 234E of the Act prospectively with effect from