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20 results for “TDS”+ Section 61clear

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Key Topics

Section 153C30Section 44B19Addition to Income18Section 143(3)14Section 914Section 153A13Section 26312Section 2506Reassessment6Disallowance

PAL MINERAL INDUSTRIES (P) LIMITED,HALDWANI vs. DC/ACIT, CENTRAL CIRCLE, HALDWANI, HALDWANI

ITA 106/DDN/2025[2013-2014]Status: DisposedITAT Dehradun12 Mar 2026AY 2013-2014

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 153ASection 153CSection 250

61. A reading of the aforesaid Satisfaction Notes would establish that jurisdictional AOs' appear to have proceeded on the premise that the moment incriminating material is unearthed in respect of a particular AY, they would have the jurisdiction and authority to invoke Section 153C in respect of all the assessment years which could otherwise form part of the "relevant assessment

PAL MINERAL INDUSTRIES (P) LIMITED,HALDWANI vs. DC/ACIT, CENTRAL CIRCLE, HALDWANI, HALDWANI

ITA 105/DDN/2025[2014-2015]Status: DisposedITAT Dehradun
6
Section 36(1)(va)4
Limitation/Time-bar3
12 Mar 2026
AY 2014-2015

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 153ASection 153CSection 250

61. A reading of the aforesaid Satisfaction Notes would establish that jurisdictional AOs' appear to have proceeded on the premise that the moment incriminating material is unearthed in respect of a particular AY, they would have the jurisdiction and authority to invoke Section 153C in respect of all the assessment years which could otherwise form part of the "relevant assessment

MOHAN PAL,HALDWANI, NAINITAL vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, HALDWANI, ACIT - DCIT, CENTRAL CIRCLE, HALDWANI

ITA 85/DDN/2024[2015-16]Status: DisposedITAT Dehradun12 Mar 2026AY 2015-16

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 132Section 143(3)Section 153ASection 153A(1)Section 153CSection 250

61. A reading of the aforesaid Satisfaction Notes would establish that jurisdictional AOs' appear to have proceeded on the premise that the moment incriminating material is unearthed in respect of a particular AY, they would have the jurisdiction and authority to invoke Section 153C in respect of all the assessment years which could otherwise form part of the "relevant assessment

MOHAN PAL,HALDWANI, NAINITAL vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, HALDWANI, ACIT - DCIT, CENTRAL CIRCLE, HALDWANI

ITA 84/DDN/2024[2014-15]Status: DisposedITAT Dehradun12 Mar 2026AY 2014-15

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 132Section 143(3)Section 153ASection 153A(1)Section 153CSection 250

61. A reading of the aforesaid Satisfaction Notes would establish that jurisdictional AOs' appear to have proceeded on the premise that the moment incriminating material is unearthed in respect of a particular AY, they would have the jurisdiction and authority to invoke Section 153C in respect of all the assessment years which could otherwise form part of the "relevant assessment

MOHAN PAL,HALDWANI, NAINITAL vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, HALDWANI, ACIT-DCIT, CENTRAL CIRCLE, HALDWANI

ITA 83/DDN/2024[2013-14]Status: DisposedITAT Dehradun12 Mar 2026AY 2013-14

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 132Section 143(3)Section 153ASection 153A(1)Section 153CSection 250

61. A reading of the aforesaid Satisfaction Notes would establish that jurisdictional AOs' appear to have proceeded on the premise that the moment incriminating material is unearthed in respect of a particular AY, they would have the jurisdiction and authority to invoke Section 153C in respect of all the assessment years which could otherwise form part of the "relevant assessment

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

ITA 5565/DEL/2013[2010-11]Status: DisposedITAT Dehradun08 Jun 2021AY 2010-11

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

61. The learned AO has raised the following grounds of appeal in ITA No. 5565/Del/2012 for the Assessment Year 2010-11:- “1. Whether on the facts and circumstances of the case, the Ld CIT(A) has erred in holding that no distinction can be made between receipts from PSC and Non-PSC Partners, ignoring the facts that the receipts from

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 2956/DEL/2013[2006-07]Status: DisposedITAT Dehradun08 Jun 2021AY 2006-07

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

61. The learned AO has raised the following grounds of appeal in ITA No. 5565/Del/2012 for the Assessment Year 2010-11:- “1. Whether on the facts and circumstances of the case, the Ld CIT(A) has erred in holding that no distinction can be made between receipts from PSC and Non-PSC Partners, ignoring the facts that the receipts from

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

ITA 3045/DEL/2013[2006-07]Status: DisposedITAT Dehradun08 Jun 2021AY 2006-07

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

61. The learned AO has raised the following grounds of appeal in ITA No. 5565/Del/2012 for the Assessment Year 2010-11:- “1. Whether on the facts and circumstances of the case, the Ld CIT(A) has erred in holding that no distinction can be made between receipts from PSC and Non-PSC Partners, ignoring the facts that the receipts from

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

ITA 5564/DEL/2013[2007-08]Status: DisposedITAT Dehradun08 Jun 2021AY 2007-08

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

61. The learned AO has raised the following grounds of appeal in ITA No. 5565/Del/2012 for the Assessment Year 2010-11:- “1. Whether on the facts and circumstances of the case, the Ld CIT(A) has erred in holding that no distinction can be made between receipts from PSC and Non-PSC Partners, ignoring the facts that the receipts from

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 5584/DEL/2013[2010-11]Status: DisposedITAT Dehradun08 Jun 2021AY 2010-11

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

61. The learned AO has raised the following grounds of appeal in ITA No. 5565/Del/2012 for the Assessment Year 2010-11:- “1. Whether on the facts and circumstances of the case, the Ld CIT(A) has erred in holding that no distinction can be made between receipts from PSC and Non-PSC Partners, ignoring the facts that the receipts from

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 5583/DEL/2013[2007-08]Status: DisposedITAT Dehradun08 Jun 2021AY 2007-08

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

61. The learned AO has raised the following grounds of appeal in ITA No. 5565/Del/2012 for the Assessment Year 2010-11:- “1. Whether on the facts and circumstances of the case, the Ld CIT(A) has erred in holding that no distinction can be made between receipts from PSC and Non-PSC Partners, ignoring the facts that the receipts from

MI OVERSEAS LTD.,NEW DELHI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 3072/DEL/2012[2009-10]Status: DisposedITAT Dehradun08 Jun 2021AY 2009-10

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

61. The learned AO has raised the following grounds of appeal in ITA No. 5565/Del/2012 for the Assessment Year 2010-11:- “1. Whether on the facts and circumstances of the case, the Ld CIT(A) has erred in holding that no distinction can be made between receipts from PSC and Non-PSC Partners, ignoring the facts that the receipts from

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

ITA 5/DDN/2022[2017-2018]Status: DisposedITAT Dehradun31 Mar 2022AY 2017-2018
For Appellant: Shri Ajay Vohra, Sr. Advocate &For Respondent: Shri T.S. Mapwal, Sr. DR
Section 143(3)Section 144C(13)Section 92C

TDS of Rs.II,95,58,717 deducted by the income-tax authorities on interest on income-tax refund. Ground No. 12: Erroneous levy of interest under section 234A of the Act 12.1 The learned AO erred in law and in facts, in levying interest under section 234A of the Act whereas the Appellant filed the return of income within

SMT. SAPNA GUPTA,HARIDWAR vs. THE PRINCIPAL COMMISSIONER OF INCOEM TAX, DEHRADUN

In the result, the appeal of the assessee is dismissed

ITA 16/DDN/2021[2009-2010]Status: DisposedITAT Dehradun08 Jun 2023AY 2009-2010

Bench: Shri Saktijit Dey & Shri M. Balaganeshassessment Year: 2009-10 Smt. Sapna Gupta, Vs The Pr. Cit, 299, Awas Vikas Colony, Dehradun. Vivek Vihar, Haridwar – 249 407, Uttarakhand. Pan: Acspg4083D (Appellant) (Respondent) Assessee By : Shri Rohit Jain, Advocate & Ms Deepashri Rao, Ca Revenue By : Shri N.S. Jangpangi, Cit, Dr Date Of Hearing : 27.04.2023 Date Of Pronouncement : 08.06.2023 Order Per M. Balaganesh, Am: This Appeal In Ita No.16/Ddn/2021 For Ay 2009-10 Arises Out Of The Order Of The Pr. Commissioner Of Income Tax (Appeals), Dehradun, [Hereinafter Referred To As „Ld. Pcit‟, In Short] In Din & Order No. Itba/Rev/F/Rev5/2020- 21/1031815348(1) Dated 27.03.2021 Against The Order Of Assessment Passed U/S 148/147 R.W.S. 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As „The Act‟) Dated 26Th/28Th December, 2018 By The Ld. Assessing Officer, Ward 1(3)(3), Haridwar (Hereinafter Referred To As „Ld. Ao‟). 2. The Only Issue To Be Decided In This Appeal Is As To Whether The Ld. Pcit Was Justified In Invoking Revisionary Jurisdiction U/S 263 Of The Act In Respect Of Disallowance Of Purchases Of Rs 33,35,500/- In The Facts & Circumstances Of The Instant Case.

For Appellant: Shri Rohit Jain, Advocate &For Respondent: Shri N.S. Jangpangi, CIT, DR
Section 147Section 148Section 263Section 263(2)

section 142(1) of the I.Tax Act, 1961, you are hereby required to submit your sale tax return for the F.Y. 2008-09, copies of road permit and „Bahati Form ‟ for the item claimed to be purchased from Meet enterprises. 2. Kindly furnish the detail of final order of VAT/Sale Tax, detail of penalty imposed by the Department, and detail

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

In the result, the appeal of the assessee is allowed

ITA 6608/DEL/2016[2012-13]Status: DisposedITAT Dehradun05 Oct 2023AY 2012-13
For Appellant: Smt. Shashi M Kapila, AdvocateFor Respondent: Shri Mayank Kumar, Addl.CIT DR
Section 143(3)Section 246ASection 271GSection 40aSection 44BSection 44D

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

JOINT COMMISSIONER OF INCOME TAX, SUBHASH ROAD DEHADUN vs. M/S TIMES SQUARE, SAHASTRADHARA ROAD

In the result, appeal of the Revenue is dismissed

ITA 42/DDN/2025[2017-18]Status: DisposedITAT Dehradun26 Sept 2025AY 2017-18
Section 143(3)Section 250Section 43CSection 69A

61,45,041/- by\nmaking various additions/disallowances.\n\n3. Against the said order, assessee filed an appeal before Ld.\nCIT(A) who vide order dated 16.01.2025, partly allowed the appeal\nof the assessee.\n\n4. Aggrieved by the order of Ld.CIT(A), Revenue is in appeal\nbefore the Tribunal by taking following grounds of appeal:-\n\n1. “On facts

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

ITA 7/DDN/2021[2016-17]Status: DisposedITAT Dehradun14 Dec 2021AY 2016-17

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

For Appellant: Sh. Ajay Vohra, Sr. AdvocateFor Respondent: Sh. N.S. Jangpangi, CIT/DR
Section 143(3)Section 144C(13)Section 144C(5)Section 44C

61,30,450/- had been capitalized and balance was accounted as work in progress. The appellant had claimed depreciation of Rs. 3,30,05,676/- on the IT infrastructure and software. The Ld. Dispute Resolution Panel has stated that even the beneficial ownership of the assent also entitles the Assessee to claim the depreciation if the test of user

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

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

ITA 908/DEL/2017[2012-13]Status: DisposedITAT Dehradun09 May 2025AY 2012-13

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 142Section 143(3)Section 14ASection 36(1)(va)

Section 2(24)(x) r.w.s. 36(1)(va) and 43B of the Act. The Ld. Senior Departmental Representative (hereinafter ‘Ld. DR’), placing reliance on the decision of the Hon’ble Supreme Court in the case of Checkmate Services P. Ltd. [(2022) 448 ITR 518 (SC)], requested for upholding of the disallowances, to which the Ld. Counsel seemed

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

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

ITA 1200/DEL/2018[2013-14]Status: DisposedITAT Dehradun09 May 2025AY 2013-14

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 142Section 143(3)Section 14ASection 36(1)(va)

Section 2(24)(x) r.w.s. 36(1)(va) and 43B of the Act. The Ld. Senior Departmental Representative (hereinafter ‘Ld. DR’), placing reliance on the decision of the Hon’ble Supreme Court in the case of Checkmate Services P. Ltd. [(2022) 448 ITR 518 (SC)], requested for upholding of the disallowances, to which the Ld. Counsel seemed

SUNIL SRIVASTAVA,HALDWANI vs. THE INCOME TAX OFFICER, WARD-2(1)(3), HALDWANI

In the result, the appeal of the assessee is allowed

ITA 10/DDN/2021[2016-17]Status: DisposedITAT Dehradun15 Sept 2023AY 2016-17

Bench: Him From Time To Time

Section 10(38)Section 143(3)Section 206CSection 44A

61,857/-, which has been claimed as exempt u/s 10(38) of the Act. The assessee also furnished the ledger account of the assessee as appearing in the books of M/s Sushil Financial Services P Ltd, Mumbai for trading of shares and commodities, which was accepted by the ld. AO. 4. Further as per Form 26AS, the assessee