SH. CHANDRA KANT CHAHAL,DEHRADUN vs. ITO, DEHRADUN

In the result, appeal of the assessee is partly allowed as indicated above

Bench: Shri Challa Nagendra Prasada N D Shrim. Balaganesh

46,80,000/- for the purpose of computing capital gains ignoring the valuation report of the DVO and the assessment made in assessee’s brother’s case wherein the valuation of the DVO was adopted for computing long term capital gains. The ld. CIT (Appeals) also did not accept the contention of the assessee for I.T.A. No. 2813/Del/2017 adopting

DAVINDER KUMAR MAGO,PUNJABI BAGH vs. DCIT/ACIT CENTRAL CIRCLE, DDN, DEHRADUN

In the result appeal of the assessee is allowed

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2019-20] Davinder Kumar Mago Vs Dcit/Acit 12/1, Punjabi Bagh, Central Circle, External Punjabi Bagh, Dehradun New Delhi-110026 Uttarakhand Pan-Ajhpm9802A Appellant Respondent Appellant By Shri Ajay Wadhwa, Adv. (Vc) Respondent By Ms. Poonam Sharma, Cit Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026 Order Per Manish Agarwal, Am : This Appeal Filed By The Assessee Against The Order By Pr.Cit (Central), Kanpur At Meerut Passed U/S 263 Of The Income Tax Act, 1861 (“The Act”) Dated 08.01.2026 Arising Out Of The Order Passed U/S 143(3) R.W.S. 147 Of The Act.

46 & 47 of the Paper Book. The AO further asked the assessee to establish genuineness and creditworthiness of all the 16 lenders. In reply thereof, the assessee vide letter dated 15.03.2024 had filed details of all the 16 lender parties comprising of confirmation, their bank statements, financial statements etc. in support of establish their identity, creditworthiness and genuineness

SH. DEVENDRA DUTT PANT,HARIDWAR vs. DCIT , UTTARKAHAND

Appeal is partly allowed in above terms

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

capital gain at a sum of Rs. 1,50,95,314/-. While doing so, assessee had claimed a deduction under section 54EC of a sum of Rs. 50,00,000/- and under section 54B of a sum of Rs. 79,97,240/- (in dispute), (kindly see page 2 of AO order and page 7 of PB for Income Tax Return

M/S. JAIPRAKASH POWER VENTURES LTD.,DEHRADUN vs. DCIT, DEHRADUN

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 Vs. Dcit, M/S, Jaiprakash Power Ventures Ltd., Circle-2, 113, Rajpur Road, Dehradun Dehradun Pan: Aaacj5463 (Appellant) (Respondent) With Assessment Year: 2008-09 Vs. M/S, Dcit, Jaiprakash Power Circle-2, Ventures Ltd., Dehradun Juit, Complex, Waknaghat, Post Office- Dumehar Bani, Kandaghat, Distt. Solan, Himachal Pradesh Pan: Aaacj5463 (Appellant) (Respondent) Assessee By Sh. Anil K. Chopra, Ca Sh. Sanjiv Choudhary, Ca Sh. V.K. Garg, Adv. Department By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 20.03.2025 Date Of Pronouncement 23.05.2025

10,652/ under the head 'profit and gains of business or profession' was worked out. Equivalent amount of deduction u/s 80-IA of the I.T. Act was claimed. Thus, the interest income was treated by the assessee as 'derived from' the eligible business of power generation. The AO treated the interest income as 'income from other sources

M/S. JAIPRAKASH POWER VENTURES LTD.,DEHRADUN vs. DCIT, DEHRADUN

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 Vs. Dcit, M/S, Jaiprakash Power Ventures Ltd., Circle-2, 113, Rajpur Road, Dehradun Dehradun Pan: Aaacj5463 (Appellant) (Respondent) With Assessment Year: 2008-09 Vs. M/S, Dcit, Jaiprakash Power Circle-2, Ventures Ltd., Dehradun Juit, Complex, Waknaghat, Post Office- Dumehar Bani, Kandaghat, Distt. Solan, Himachal Pradesh Pan: Aaacj5463 (Appellant) (Respondent) Assessee By Sh. Anil K. Chopra, Ca Sh. Sanjiv Choudhary, Ca Sh. V.K. Garg, Adv. Department By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 20.03.2025 Date Of Pronouncement 23.05.2025

10,652/ under the head 'profit and gains of business or profession' was worked out. Equivalent amount of deduction u/s 80-IA of the I.T. Act was claimed. Thus, the interest income was treated by the assessee as 'derived from' the eligible business of power generation. The AO treated the interest income as 'income from other sources

DCIT, DEHRADUN vs. M/S JAI PRAKASH POWER VENTURE LTD., H.P.

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 Vs. Dcit, M/S, Jaiprakash Power Ventures Ltd., Circle-2, 113, Rajpur Road, Dehradun Dehradun Pan: Aaacj5463 (Appellant) (Respondent) With Assessment Year: 2008-09 Vs. M/S, Dcit, Jaiprakash Power Circle-2, Ventures Ltd., Dehradun Juit, Complex, Waknaghat, Post Office- Dumehar Bani, Kandaghat, Distt. Solan, Himachal Pradesh Pan: Aaacj5463 (Appellant) (Respondent) Assessee By Sh. Anil K. Chopra, Ca Sh. Sanjiv Choudhary, Ca Sh. V.K. Garg, Adv. Department By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 20.03.2025 Date Of Pronouncement 23.05.2025

10,652/ under the head 'profit and gains of business or profession' was worked out. Equivalent amount of deduction u/s 80-IA of the I.T. Act was claimed. Thus, the interest income was treated by the assessee as 'derived from' the eligible business of power generation. The AO treated the interest income as 'income from other sources

M/S. JAIPRAKASH POWER VENTURES LTD.,,H.P. vs. DCIT, DEHRADUN

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 Vs. Dcit, M/S, Jaiprakash Power Ventures Ltd., Circle-2, 113, Rajpur Road, Dehradun Dehradun Pan: Aaacj5463 (Appellant) (Respondent) With Assessment Year: 2008-09 Vs. M/S, Dcit, Jaiprakash Power Circle-2, Ventures Ltd., Dehradun Juit, Complex, Waknaghat, Post Office- Dumehar Bani, Kandaghat, Distt. Solan, Himachal Pradesh Pan: Aaacj5463 (Appellant) (Respondent) Assessee By Sh. Anil K. Chopra, Ca Sh. Sanjiv Choudhary, Ca Sh. V.K. Garg, Adv. Department By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 20.03.2025 Date Of Pronouncement 23.05.2025

10,652/ under the head 'profit and gains of business or profession' was worked out. Equivalent amount of deduction u/s 80-IA of the I.T. Act was claimed. Thus, the interest income was treated by the assessee as 'derived from' the eligible business of power generation. The AO treated the interest income as 'income from other sources

MANAV JOHAR,RISHIKESH vs. DCIT, CENTRAL CIRCLE, DEHRADUN

capital gain and other sources. The assessee had filed the return of income declaring total income at Rs. 22,13,440/- and agricultural income of Rs. 46,92,034/-. The return was processed u/s 143(1) of the Income Tax Act, 1961 (hereinafter called ‘the Act’). A search and seizure operation was conducted

MEENA JOHAR,RISHIKESH vs. DCIT, CENTRAL CIRCLE, DEHRADUN

capital gain and other sources. The assessee had filed the return of income declaring total income at Rs. 22,13,440/- and agricultural income of Rs. 46,92,034/-. The return was processed u/s 143(1) of the Income Tax Act, 1961 (hereinafter called ‘the Act’). A search and seizure operation was conducted

MANAV JOHAR,RISHIKESH vs. DCIT, CENTRAL CIRCLE, DEHRADUN

capital gain and other sources. The assessee had filed the return of income declaring total income at Rs. 22,13,440/- and agricultural income of Rs. 46,92,034/-. The return was processed u/s 143(1) of the Income Tax Act, 1961 (hereinafter called ‘the Act’). A search and seizure operation was conducted

MANSI JOHAR,RISHIKESH vs. DCIT, CENTRAL CIRCLE, DEHRADUN

capital gain and other sources. The assessee had filed the return of income declaring total income at Rs. 22,13,440/- and agricultural income of Rs. 46,92,034/-. The return was processed u/s 143(1) of the Income Tax Act, 1961 (hereinafter called ‘the Act’). A search and seizure operation was conducted

MEENA JOHAR,RISHIKESH vs. DCIT, CENTRAL CIRCLE, DEHRADUN

capital gain and other sources. The assessee had filed the return of income declaring total income at Rs. 22,13,440/- and agricultural income of Rs. 46,92,034/-. The return was processed u/s 143(1) of the Income Tax Act, 1961 (hereinafter called ‘the Act’). A search and seizure operation was conducted

MANSI JOHAR,RISHIKESH vs. DCIT, CENTRAL CIRCLE, DEHRADUN

capital gain and other sources. The assessee had filed the return of income declaring total income at Rs. 22,13,440/- and agricultural income of Rs. 46,92,034/-. The return was processed u/s 143(1) of the Income Tax Act, 1961 (hereinafter called ‘the Act’). A search and seizure operation was conducted

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

46, E.C. Road, Aayakar Bhawan, 13-A, Subhash Road, Vs. Dehradun, Uttarakhand. Dehradun- 248001,Uttarakhand. PAN No.AADCH1061Q अपीलाथ" Appellant ""यथ"/Respondent Assessee by Shri Amit Arora, CA &Shri Vishal Mishra, CA Revenue by Shri Mohan Lal Joshi, Sr. DR सुनवाईक"तारीख/ Date of hearing: 11.02.2026 18.02.2026 उ"ोषणाक"तारीख/Pronouncement on आदेश /O R D E R PERSANJAY AWASTHI, ACCOUNTANT

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

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

46 of the judgment dated 25.01.2012 rendered in ITA No. 4653/Del/2010] wherein the Hon’ble IT AT has categorically held that the w.e.f. Asstt. Year 2011-12, FTS, even if rendered in connection with oil exploration, will be assessable u/s 44DA/115A and not u/s 44BB of the Act. 4. Whether on the facts and circumstances of the case

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

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

46,607 being the difference of depreciation amount between the tax audit report and the computation. 10.2 The learned AO / DRP erred in not appreciating that this difference is on account ofdepreciation claimed on Global IT & T expenditure and that depreciation claim on GlobalIT & T expenditure was allowable as held by the Hon’ble ITAT in Appellant’s own case

DCIT (INTERNATIONAL TAXATION),CIRCLE-I, DEHRADUN vs. HALLIBURTON OFFSHORE SERVICES INC., DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

46, E.C. Road, Circle-1, Dehradun-248001 Dehradun (APPELLANT) (RESPONDENT) PAN No. AAACH5154M Assessee by: Sh. Salil Kapoor, Sh. S. Lalchandani, Sh. T. Chanana, Ms. Ananya Kapoor, Advs. Revenue by: Sh. Mithun Shete, Sr. DR Date of Hearing: 19.03.2025 Date of Pronouncement: 07.05.2025 ORDER Per Satbeer Singh Godara, Judicial Member: This assessee’s appeal ITA No. 6026/Del/2017 with the Revenue

DCIT (INTERNATIONAL TAXATION),CIRCLE-I, DEHRADUN vs. HALLIBURTON OFFSHORE SERVICES INC., DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

46, E.C. Road, Circle-1, Dehradun-248001 Dehradun (APPELLANT) (RESPONDENT) PAN No. AAACH5154M Assessee by: Sh. Salil Kapoor, Sh. S. Lalchandani, Sh. T. Chanana, Ms. Ananya Kapoor, Advs. Revenue by: Sh. Mithun Shete, Sr. DR Date of Hearing: 19.03.2025 Date of Pronouncement: 07.05.2025 ORDER Per Satbeer Singh Godara, Judicial Member: This assessee’s appeal ITA No. 6026/Del/2017 with the Revenue

HALLIBURTON OFFSHORE SERVICES INC.,NOIDA vs. DCIT (INTERNATIONAL TAXATION), CIRCLE-1, DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

46, E.C. Road, Circle-1, Dehradun-248001 Dehradun (APPELLANT) (RESPONDENT) PAN No. AAACH5154M Assessee by: Sh. Salil Kapoor, Sh. S. Lalchandani, Sh. T. Chanana, Ms. Ananya Kapoor, Advs. Revenue by: Sh. Mithun Shete, Sr. DR Date of Hearing: 19.03.2025 Date of Pronouncement: 07.05.2025 ORDER Per Satbeer Singh Godara, Judicial Member: This assessee’s appeal ITA No. 6026/Del/2017 with the Revenue