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17 results for “TDS”+ Section 70clear

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Key Topics

Section 44B25Section 915Addition to Income13Section 143(3)9Section 2637Disallowance6Section 115A4Section 44D4Section 134Section 40A(2)

DY. COMMISSIONER OF INCOME TAX, DEHRADUN vs. HALLIBURTON WORLDWIDE GMBH, DEHRADUN

In the result, the appeal is dismissed

ITA 250/DDN/2025[2016-17]Status: DisposedITAT Dehradun18 Feb 2026AY 2016-17

Bench: Shri Yogesh Kumar Us & Shri Sanjay Awasthiआ.अ.सं/.I.T.A No.250/Ddn/2025 िनधा"रणवष"/Assessment Year:2016-17 बनाम Dy. Commissioner Of Income Tax, Halliburton Worldwide Gmbh 1St Floor, Ida, 46, E.C. Road, Aayakar Bhawan, 13-A, Subhash Road, Vs. Dehradun, Uttarakhand. Dehradun- 248001,Uttarakhand. Pan No.Aadch1061Q अपीलाथ" Appellant ""यथ"/Respondent

Section 115ASection 250Section 9(1)(vi)

70,934,733 as fees for technical services under section 9(1 )(vii) of the Act as opposed to the claim of the appellant that its business profits in the absence of PE are not chargeable to tax in India………….. 5.2.3 During the year under consideration, the appellant has undertaken four contracts with Indian Companies. Out of these four contracts

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

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

4
Permanent Establishment2
Survey u/s 133A2
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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

In the result, appeal of the assessee in ITA No

ITA 1315/DEL/2017[2008-09]Status: DisposedITAT Dehradun22 Dec 2023AY 2008-09
Section 143(3)Section 234C

70,741/-. It was further observed that cost of revenues were shown under the following three sub-heads for an aggregate sum of Rs. 23,91,08,293/-: (i) Hook up and commissioning Rs. 89,04,947/- (ii) Insurance Rs. 22,66,85,140/- (iii) Pre-engineering and survey Rs. 35,18,206/- 18. It was further noticed that

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

In the result, appeal of the assessee in ITA No

ITA 873/DEL/2017[2012-13]Status: DisposedITAT Dehradun22 Dec 2023AY 2012-13
Section 143(3)Section 234C

70,741/-. It was further observed that cost of revenues were shown under the following three sub-heads for an aggregate sum of Rs. 23,91,08,293/-: (i) Hook up and commissioning Rs. 89,04,947/- (ii) Insurance Rs. 22,66,85,140/- (iii) Pre-engineering and survey Rs. 35,18,206/- 18. It was further noticed that

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

ITA 6437/DEL/2014[2011-12]Status: DisposedITAT Dehradun05 May 2022AY 2011-12

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

Section 143(3)Section 44BSection 44DSection 9

TDS has not been given. The Id. AO must do so at the time of giving effect to this order. 10. Ground no. 9 challenges the levy of interest u/s 234B of the Act. This ground is allowed following the case of Maersk reported in 334 ITR 79 (UK). 11. Ground nos. 10 and 11 challenge the initiation of penalty

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

section 43CA of the Act and further deletion of addition of INR\n2,24,34,000/- made u/s 69A of the Act r.w.s. 115BBE of the Act\ntowards cash deposits during demonetization.\n\n6. Regarding Ground of appeal Nos. 1 to 3 taken against the\ndeletion of additions of cash deposit during the demonetization\nperiod in Specified bank notes

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

70,464,943 Safety Environment & 11,355 Materials Technical & Engineering 316,786,095 Services Less: Reversal of Water (8,344,443) Transportation & other charges Total BG Exclusive 494,452,392 Production Cost. The above expenditure are in the nature of tanker expenditure, tug and boat expenditure, safety environment and material expenditure as well as technical and engineering services. During

INSTITUTE OF CLINICAL RESEARCH (INDIA) SOCIETY,DEHRADUN vs. ACIT, DEHRADUN

In the result, the appeal filed by the assessee in ITA No

ITA 4207/DEL/2010[2006-07]Status: DisposedITAT Dehradun15 Jan 2025AY 2006-07

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri A.S. Rana, Sr. DR
Section 11Section 13Section 36(1)(iii)Section 40A(2)Section 40A(2)(b)Section 68

70% of the fee collected paid as service charges was not excessive. The ld. counsel for the assessee relied upon the decision of the Hon'ble Delhi High Court in the case of Siddhomal & Sons 122 ITR 839. 13. We have heard the rival submissions and have perused the relevant material on record. We find that

DCIT, DEHRADUN vs. M/S INSTITUTE OF CLINICAL RESEARCH (INDIA) SOCIETY,, DEHRADUN

In the result, the appeal filed by the assessee in ITA No

ITA 3927/DEL/2012[2008-09]Status: DisposedITAT Dehradun15 Jan 2025AY 2008-09

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri A.S. Rana, Sr. DR
Section 11Section 13Section 36(1)(iii)Section 40A(2)Section 40A(2)(b)Section 68

70% of the fee collected paid as service charges was not excessive. The ld. counsel for the assessee relied upon the decision of the Hon'ble Delhi High Court in the case of Siddhomal & Sons 122 ITR 839. 13. We have heard the rival submissions and have perused the relevant material on record. We find that