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

9(l)(vii) read with Section 44DA of the Act and are eligible for treatment u/s 44BB of the Act, not appreciating the findings of the AO that the supply of the material is intrinsically linked with the performance of mud engineering services under composite contracts with the recipients of services. 2. Whether on the facts and circumstances

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

9(l)(vii) read with Section 44DA of the Act and are eligible for treatment u/s 44BB of the Act, not appreciating the findings of the AO that the supply of the material is intrinsically linked with the performance of mud engineering services under composite contracts with the recipients of services. 2. Whether on the facts and circumstances

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

9(l)(vii) read with Section 44DA of the Act and are eligible for treatment u/s 44BB of the Act, not appreciating the findings of the AO that the supply of the material is intrinsically linked with the performance of mud engineering services under composite contracts with the recipients of services. 2. Whether on the facts and circumstances

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

9(l)(vii) read with Section 44DA of the Act and are eligible for treatment u/s 44BB of the Act, not appreciating the findings of the AO that the supply of the material is intrinsically linked with the performance of mud engineering services under composite contracts with the recipients of services. 2. Whether on the facts and circumstances

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

9(l)(vii) read with Section 44DA of the Act and are eligible for treatment u/s 44BB of the Act, not appreciating the findings of the AO that the supply of the material is intrinsically linked with the performance of mud engineering services under composite contracts with the recipients of services. 2. Whether on the facts and circumstances

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

9(l)(vii) read with Section 44DA of the Act and are eligible for treatment u/s 44BB of the Act, not appreciating the findings of the AO that the supply of the material is intrinsically linked with the performance of mud engineering services under composite contracts with the recipients of services. 2. Whether on the facts and circumstances

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

vii) of the Act. The services provided by the Assessee were very much in connection with exploration of mineral oil. 17. Similarly, serial no. 10, 15, 22 and 44 of the table inserted in the ONGC Ltd. case (supra) covers the services of data processing given by the assessee with the scope of work involved, in the contracts examined

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

vii) of the Act. The services provided by the Assessee were very much in connection with exploration of mineral oil. 17. Similarly, serial no. 10, 15, 22 and 44 of the table inserted in the ONGC Ltd. case (supra) covers the services of data processing given by the assessee with the scope of work involved, in the contracts examined

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

vii) of the Act. The services provided by the Assessee were very much in connection with exploration of mineral oil. 17. Similarly, serial no. 10, 15, 22 and 44 of the table inserted in the ONGC Ltd. case (supra) covers the services of data processing given by the assessee with the scope of work involved, in the contracts examined

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

vii) of the Act. The services provided by the Assessee were very much in connection with exploration of mineral oil. 17. Similarly, serial no. 10, 15, 22 and 44 of the table inserted in the ONGC Ltd. case (supra) covers the services of data processing given by the assessee with the scope of work involved, in the contracts examined

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

In the result, the appeal is dismissed

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

vii) of the Act. 4. The Appellant craves leave to add, amend, alter vary and / or withdraw any or all the above grounds of appeal.” 2. Before us, the Ld. DR read out various portions from the Ld. AO’s orders and supported the finding on facts. 2.1 Per contra, the Ld. AR relied on the findings

GULF PIPING COMPANY WLL,UNITED ARAB EMIRATES vs. DY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

section 9(1)(vii) of the Act. 5. The Revenue vehemently argues in this factual backdrop that although there is double tax avoidance between India and UAE “DTAA”, but, at the same time, it does not cover such fees for technical services assessment there under. It’s case accordingly is that the learned lower authorities have rightly assessed the assessee

GULF PIPING COMPANY WLL,UNITED ARAB EMIRATES vs. DY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

section 9(1)(vii) of the Act. 5. The Revenue vehemently argues in this factual backdrop that although there is double tax avoidance between India and UAE “DTAA”, but, at the same time, it does not cover such fees for technical services assessment there under. It’s case accordingly is that the learned lower authorities have rightly assessed the assessee

GULF PIPING COMPANY WLL,ABU DHABI vs. DY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

section 9(1)(vii) of the Act. 5. The Revenue vehemently argues in this factual backdrop that although there is double tax avoidance between India and UAE “DTAA”, but, at the same time, it does not cover such fees for technical services assessment there under. It’s case accordingly is that the learned lower authorities have rightly assessed the assessee

DDIT, DEHRADUN vs. M/S. SMITH INTERNATIONAL INC., DEHRADUN

In the result, both the appeals of the assessee are allowed and both the appeals of the Revenue are dismissed

Bench: Sh. Amit Shukladr. B. R. R. Kumarita No. 4561/Del/2013 : Asstt. Year : 2009-10 Ita No. 3824/Del/2014 : Asstt. Year : 2010-11 Smith International Inc., Vs Adit, 806-807, Powai Plaza, Central International Taxation, Avenue, Hiranandani Garden, Dehradun Powai, Mumbai-400076 (Appellant) (Respondent) Pan No. Aahcs3148R

vii) of sub- section (1) of section 9; (b) "royalty" shall have the same meaning as in Explanation 2 to clause (vi) of sub-section (1) of section 9; (c) "permanent establishment" shall have the same meaning as in clause (iiia) of section 92F.’.” 8. Aggrieved with the order of the Assessing Officer, the assessee is filed an appeal before

SMITH INTERNATIONAL INC.,MUMBAI vs. ADIT, DEHRADUN

In the result, both the appeals of the assessee are allowed and both the appeals of the Revenue are dismissed

Bench: Sh. Amit Shukladr. B. R. R. Kumarita No. 4561/Del/2013 : Asstt. Year : 2009-10 Ita No. 3824/Del/2014 : Asstt. Year : 2010-11 Smith International Inc., Vs Adit, 806-807, Powai Plaza, Central International Taxation, Avenue, Hiranandani Garden, Dehradun Powai, Mumbai-400076 (Appellant) (Respondent) Pan No. Aahcs3148R

vii) of sub- section (1) of section 9; (b) "royalty" shall have the same meaning as in Explanation 2 to clause (vi) of sub-section (1) of section 9; (c) "permanent establishment" shall have the same meaning as in clause (iiia) of section 92F.’.” 8. Aggrieved with the order of the Assessing Officer, the assessee is filed an appeal before

SMITH INTERNATIONAL INC.,MUMBAI vs. ADIT, DEHRADUN

In the result, both the appeals of the assessee are allowed and both the appeals of the Revenue are dismissed

Bench: Sh. Amit Shukladr. B. R. R. Kumarita No. 4561/Del/2013 : Asstt. Year : 2009-10 Ita No. 3824/Del/2014 : Asstt. Year : 2010-11 Smith International Inc., Vs Adit, 806-807, Powai Plaza, Central International Taxation, Avenue, Hiranandani Garden, Dehradun Powai, Mumbai-400076 (Appellant) (Respondent) Pan No. Aahcs3148R

vii) of sub- section (1) of section 9; (b) "royalty" shall have the same meaning as in Explanation 2 to clause (vi) of sub-section (1) of section 9; (c) "permanent establishment" shall have the same meaning as in clause (iiia) of section 92F.’.” 8. Aggrieved with the order of the Assessing Officer, the assessee is filed an appeal before

ADIT, DEHRADUN vs. M/S. SMITH INTERNATIONAL INC., DEHRADUN

In the result, both the appeals of the assessee are allowed and both the appeals of the Revenue are dismissed

Bench: Sh. Amit Shukladr. B. R. R. Kumarita No. 4561/Del/2013 : Asstt. Year : 2009-10 Ita No. 3824/Del/2014 : Asstt. Year : 2010-11 Smith International Inc., Vs Adit, 806-807, Powai Plaza, Central International Taxation, Avenue, Hiranandani Garden, Dehradun Powai, Mumbai-400076 (Appellant) (Respondent) Pan No. Aahcs3148R

vii) of sub- section (1) of section 9; (b) "royalty" shall have the same meaning as in Explanation 2 to clause (vi) of sub-section (1) of section 9; (c) "permanent establishment" shall have the same meaning as in clause (iiia) of section 92F.’.” 8. Aggrieved with the order of the Assessing Officer, the assessee is filed an appeal before