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

56. Ground number 7 – 8 of the appeal of the assessee is with respect to the taxability of reimbursement in the nature of service tax paid which is covered in favour of the assessee is aggrieved by the parties by the decision of the honourable jurisdictional High Court in 414 ITR 1 and also decided by us in appeal

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

56. Ground number 7 – 8 of the appeal of the assessee is with respect to the taxability of reimbursement in the nature of service tax paid which is covered in favour of the assessee is aggrieved by the parties by the decision of the honourable jurisdictional High Court in 414 ITR 1 and also decided by us in appeal

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

56. Ground number 7 – 8 of the appeal of the assessee is with respect to the taxability of reimbursement in the nature of service tax paid which is covered in favour of the assessee is aggrieved by the parties by the decision of the honourable jurisdictional High Court in 414 ITR 1 and also decided by us in appeal

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

56. Ground number 7 – 8 of the appeal of the assessee is with respect to the taxability of reimbursement in the nature of service tax paid which is covered in favour of the assessee is aggrieved by the parties by the decision of the honourable jurisdictional High Court in 414 ITR 1 and also decided by us in appeal

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

56. Ground number 7 – 8 of the appeal of the assessee is with respect to the taxability of reimbursement in the nature of service tax paid which is covered in favour of the assessee is aggrieved by the parties by the decision of the honourable jurisdictional High Court in 414 ITR 1 and also decided by us in appeal

ACIT, CIRCLE- 3, NAINITAL vs. KUMAON MANDAL VIKAS NIGAM LTD., NAINITAL

In the result, both appeals of the Revenue are partly allowed as above

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

vii) Taxability of contract receipt of Rs.1,38,08,610/- on accrual basis (viii) Disallowance of interest under section 14A. 3.1 Vide 5 grounds; the Revenue has raised following issues (i) Disallowance of employees’ contribution in ECGI under section 36(1)(va) r.w.s.2(24)(x) of the Act. (ii) Disallowance of interest of Rs.50,50,442/- on Government loans/ advances

ACIT, NAINITAL vs. M/S. KUMAON MANDAL VIKAS NIGAM LTD., NAINITAL

In the result, both appeals of the Revenue are partly allowed as above

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

vii) Taxability of contract receipt of Rs.1,38,08,610/- on accrual basis (viii) Disallowance of interest under section 14A. 3.1 Vide 5 grounds; the Revenue has raised following issues (i) Disallowance of employees’ contribution in ECGI under section 36(1)(va) r.w.s.2(24)(x) of the Act. (ii) Disallowance of interest of Rs.50,50,442/- on Government loans/ advances

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

In the result, appeal of the assessee in ITA No

2) That the contract under consideration was a composite contract; and 3) That the entire contract revenues (both inside India and outside India) were attributable to the alleged PE in India and chargeable to tax in India on income computed @25% deemed profit rate. 4. The income has been computed by the ld AO after holding „inside India revenue

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

In the result, appeal of the assessee in ITA No

2) That the contract under consideration was a composite contract; and 3) That the entire contract revenues (both inside India and outside India) were attributable to the alleged PE in India and chargeable to tax in India on income computed @25% deemed profit rate. 4. The income has been computed by the ld AO after holding „inside India revenue