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
vi) of the Act and taxing income from non-PSC contractors under section 44DA of the Act.
ii. Further, income from provision of various services has been treated as fees for technical services
(‘FTS’) under 9(l)(vii) of the Act, applying estimated profit rate of 25% as against said income offered to tax under section 44BB