RAJIV KUMAR TIWARI,SAHARANPUR vs. DCIT-ACIT- CEN CIR DDN, DEHRADUN

In the result, the appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Vimal Kumar & Shri Brajesh Kumar Singhassessment Year: 2018-19 Rajiv Kumar Tiwari, Acit, Central Circle, A-7, Awas Vikas, Dehradun, Income Tax Office, 52/1, Delhi Road, Vs Rajpur Road, Dehradun Saharanpur, Uttarakhand-248001 Uttar Pradesh-247001 Pan-Adfpt9463L Appellant Respondent

section 201(1) of the Act, wherein, for non-deduction of TDS, the assessee is treated as deemed to be an assessee in default in respect of such tax. Therefore, in respect of the above disallowance u/s 40(a)(ia) of the Act, there is a provision for filing of the appeal which the assessee has filed and the same

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

In the result, appeal of the assessee in ITA No

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 the insurance was paid by the assessee to IFFCO-TOKIO General Insurance Company Ltd. and the policy taken was in the name of Samsung Heavy Industries

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

In the result, appeal of the assessee in ITA No

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 the insurance was paid by the assessee to IFFCO-TOKIO General Insurance Company Ltd. and the policy taken was in the name of Samsung Heavy Industries

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

91,520/- on 30th March, 2018. Since the assessee had entered into certain international transactions with its AE, the AO referred the matter to the TPO for determination of the ALP of the international transaction u/s 92CA(3) of the IT Act. The TPO proposed an upward adjustment of Rs.1,81,73,48,726/- in respect of intra group services