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

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

iv) Whether on the facts and in the circumstances of the case and in law, the CIT (A) has erred in ignoring the nature of activities and scope of work in respect of the Annual Maintenance Contract Services, support for software and training, etc provided by the assessee lead to the infallible conclusion that the receipts of the assessee were

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

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

iv) Whether on the facts and in the circumstances of the case and in law, the CIT (A) has erred in ignoring the nature of activities and scope of work in respect of the Annual Maintenance Contract Services, support for software and training, etc provided by the assessee lead to the infallible conclusion that the receipts of the assessee were

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

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

iv) Whether on the facts and in the circumstances of the case and in law, the CIT (A) has erred in ignoring the nature of activities and scope of work in respect of the Annual Maintenance Contract Services, support for software and training, etc provided by the assessee lead to the infallible conclusion that the receipts of the assessee were

DIGVIJAY SINGH,DEHRADIM vs. DCIT,CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee for assessment year

IV [hereinafter referred to as ‘CIT(A)’], Kanpur, pertaining to assessment years 2015-16 and 2016-17 respectively. AY: 2015-16 2. The only effective issue to be decided in this appeal is as to whether the learned CIT(A) was justified in confirming the addition made by learned Assessing Officer in the sum of Rs.1 crore as unexplained investments

DIGVIJAY SINGH,DEHRADUN vs. DCIT,CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee for assessment year

IV [hereinafter referred to as ‘CIT(A)’], Kanpur, pertaining to assessment years 2015-16 and 2016-17 respectively. AY: 2015-16 2. The only effective issue to be decided in this appeal is as to whether the learned CIT(A) was justified in confirming the addition made by learned Assessing Officer in the sum of Rs.1 crore as unexplained investments

KARAM SAFETY PRIVATE LIMITED,SITARGANJ vs. THE INCOME TAX OFFICER, WARD-2(3)(5), UDHAM SINGH NAGAR

In the result, both the appeals of the assessee are allowed and that of the Stay Applications are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

capital of other company which remains in existence and continues its undertaking but the context in which the term is used may show that it is intended to include such an acquisition. See: Halsbury's Laws of England (4th edition volume 7 para 1539). Two companies may join to form a new company, but there may be absorption or blending

KARAM SAFETY PRIVATE LIMITED,UDHAM SINGH NAGAR vs. THE INCOME TAX OFFICER, WARD-2(3)(5), UDHAM SINGH NAGAR

In the result, both the appeals of the assessee are allowed and that of the Stay Applications are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

capital of other company which remains in existence and continues its undertaking but the context in which the term is used may show that it is intended to include such an acquisition. See: Halsbury's Laws of England (4th edition volume 7 para 1539). Two companies may join to form a new company, but there may be absorption or blending

AKRAM,ROORKEE vs. DCIT, CIRCLE, HARIDWAR

Appeal is partly allowed for statistical purposes in above terms

Bench: Sh. Satbeer Singh Godara & Sh. Naveen Chandra

iv. Profit earned Rs. 57,65,625/- 8. As already pointed no compliance has been made to the various opportunities for hearing that have been afforded to the assessee during the course of appeal. In the circumstances, the merits of the case are being decided on the basis of grounds of appeal filed by the assessee. 9. Basically the issue

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

Appeal is partly allowed in above terms

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

iv) Photographs of agricultural activity being carried out by assessee at the time of sale of land (kindly see pages 223 to 224 of PB). v) Photographs of deep drain alongside aforesaid land used for irrigation activities (kindly see pages 221 to 222 of PB). vi) Copy of certificate of Sh. Ram Singh, husband of Smt. Saraswati Deviji, stating that

M/S THDC INDIA LIMITED, RISHIKESH,RISHIKESH vs. PCIT, DEHRADUN, DEHRADUN

In the result, appeal of the assessee is partly allowed

IV, ICAI\nguidance note & Section 5 r/w section 145 of the Income Tax Act.\n3.5. During the assessment proceedings, Ld. AO had directed the Appellant vide\nshow cause notice dated 15.3.2022 as to why Rs. 280,34,10,000 be not added\nto the total income of the assessee on account of late payment surcharge\nleviable on debtors outstanding

DCIT, CIRCLE- II, INTL. TAXATION, DEHRADUN vs. WEATHERFORD OEL TOOLS MIDDLE EAST LTD., DEHRADUN

The appeal of the revenue is dismissed and cross objection of the assessee is allowed

Bench: Shri Kul Bharat & Shri M. Balaganesh(Through Video Conferencing) Dcit, Vs. M/S. Weatherford Oil Tools Me Ltd, C/O. Nangia & Co, 3Rd Floor, Ncr Circle-Ii, International Taxation, Dehradun Plaza, Municipal, No. 24A, New Cantt Road, Dehradun (Appellant) (Respondent) Pan: Aaacw1542G

Section 44BB(2) of the Act as it is not an amount received by the assessee on account of service provided by them for the extraction or production of mineral oil and that the same is merely a tax levied on service which had been recovered and paid to the account of the Central Govt. Therefore, the same would

SHRI SHAHAZAD ALI,DEHRADUN vs. ITO, DEHRADUN

In the result, appeals are partly allowed as indicated above

Bench: Shri Saktijit Dey, Vice- & Shri M. Balaganeshassessment Year: 2007-08 Salim Ali, Vill. Ajabpur Kalan, Versus Income-Tax Officer, Post Ajabpur, Dehradun. Ward 2(1), Dehradun. Pan:Bapba5312H (Appellant) (Respondent) Assessment Year: 2007-08 Azad Ali, Vill. Ajabpur Kalan, Versus Income-Tax Officer, Post Ajabpur, Dehradun. Ward 2(1), Dehradun. Pan:Azvpa8477F (Respondent) (Appellant) Assessment Year: 2007-08 Shahzad Ali, Vill. Ajabpur Kalan, Versus Income-Tax Officer, Post Ajabpur, Dehradun. Ward 2(1), Dehradun. Pan:Azopa9077A (Respondent) (Appellant) Assessees By : Sh. Saurabh Gupta, Ca & Sh. Rishabh Gupta, Ca Revenue By : Sh. A.S. Rana, Cit/Dr Date Of Hearing : 19.06.2023 Date Of Pronouncement: 23.06.2023

1), Dehradun. PAN:AZOPA9077A (Respondent) (Appellant) Assessees by : Sh. Saurabh Gupta, CA & Sh. Rishabh Gupta, CA Revenue by : Sh. A.S. Rana, CIT/DR Date of hearing : 19.06.2023 Date of pronouncement: 23.06.2023 ITA No. 1570, 1572 & 1574/Del/2015 ORDER Captioned appeals are by three different assessees against three separate orders of learned Commissioner of Income-tax (Appeals), Dehradun pertaining to the assessment year

SHRI AZAD ALI,DEHRADUN vs. ITO, DEHRADUN

In the result, appeals are partly allowed as indicated above

Bench: Shri Saktijit Dey, Vice- & Shri M. Balaganeshassessment Year: 2007-08 Salim Ali, Vill. Ajabpur Kalan, Versus Income-Tax Officer, Post Ajabpur, Dehradun. Ward 2(1), Dehradun. Pan:Bapba5312H (Appellant) (Respondent) Assessment Year: 2007-08 Azad Ali, Vill. Ajabpur Kalan, Versus Income-Tax Officer, Post Ajabpur, Dehradun. Ward 2(1), Dehradun. Pan:Azvpa8477F (Respondent) (Appellant) Assessment Year: 2007-08 Shahzad Ali, Vill. Ajabpur Kalan, Versus Income-Tax Officer, Post Ajabpur, Dehradun. Ward 2(1), Dehradun. Pan:Azopa9077A (Respondent) (Appellant) Assessees By : Sh. Saurabh Gupta, Ca & Sh. Rishabh Gupta, Ca Revenue By : Sh. A.S. Rana, Cit/Dr Date Of Hearing : 19.06.2023 Date Of Pronouncement: 23.06.2023

1), Dehradun. PAN:AZOPA9077A (Respondent) (Appellant) Assessees by : Sh. Saurabh Gupta, CA & Sh. Rishabh Gupta, CA Revenue by : Sh. A.S. Rana, CIT/DR Date of hearing : 19.06.2023 Date of pronouncement: 23.06.2023 ITA No. 1570, 1572 & 1574/Del/2015 ORDER Captioned appeals are by three different assessees against three separate orders of learned Commissioner of Income-tax (Appeals), Dehradun pertaining to the assessment year

SHRI SALIM ALI,DEHRADUN vs. ITO, DEHRADUN

In the result, appeals are partly allowed as indicated above

Bench: Shri Saktijit Dey, Vice- & Shri M. Balaganeshassessment Year: 2007-08 Salim Ali, Vill. Ajabpur Kalan, Versus Income-Tax Officer, Post Ajabpur, Dehradun. Ward 2(1), Dehradun. Pan:Bapba5312H (Appellant) (Respondent) Assessment Year: 2007-08 Azad Ali, Vill. Ajabpur Kalan, Versus Income-Tax Officer, Post Ajabpur, Dehradun. Ward 2(1), Dehradun. Pan:Azvpa8477F (Respondent) (Appellant) Assessment Year: 2007-08 Shahzad Ali, Vill. Ajabpur Kalan, Versus Income-Tax Officer, Post Ajabpur, Dehradun. Ward 2(1), Dehradun. Pan:Azopa9077A (Respondent) (Appellant) Assessees By : Sh. Saurabh Gupta, Ca & Sh. Rishabh Gupta, Ca Revenue By : Sh. A.S. Rana, Cit/Dr Date Of Hearing : 19.06.2023 Date Of Pronouncement: 23.06.2023

1), Dehradun. PAN:AZOPA9077A (Respondent) (Appellant) Assessees by : Sh. Saurabh Gupta, CA & Sh. Rishabh Gupta, CA Revenue by : Sh. A.S. Rana, CIT/DR Date of hearing : 19.06.2023 Date of pronouncement: 23.06.2023 ITA No. 1570, 1572 & 1574/Del/2015 ORDER Captioned appeals are by three different assessees against three separate orders of learned Commissioner of Income-tax (Appeals), Dehradun pertaining to the assessment year

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

1,34,92,99,600 7. Debentures Life Insurance Corpn. 63,30,00,000 8. Debentures Life Insurance Corpn. 52,70,00,000 Total 11,60,82,46,166 Copies of the sanction letters were also furnished for perusal. It is noticed that all these loans were sanctioned to the assessee for the purpose of setting up the Vishnuprayag Hydro

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

1,34,92,99,600 7. Debentures Life Insurance Corpn. 63,30,00,000 8. Debentures Life Insurance Corpn. 52,70,00,000 Total 11,60,82,46,166 Copies of the sanction letters were also furnished for perusal. It is noticed that all these loans were sanctioned to the assessee for the purpose of setting up the Vishnuprayag Hydro

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

1,34,92,99,600 7. Debentures Life Insurance Corpn. 63,30,00,000 8. Debentures Life Insurance Corpn. 52,70,00,000 Total 11,60,82,46,166 Copies of the sanction letters were also furnished for perusal. It is noticed that all these loans were sanctioned to the assessee for the purpose of setting up the Vishnuprayag Hydro

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

1,34,92,99,600 7. Debentures Life Insurance Corpn. 63,30,00,000 8. Debentures Life Insurance Corpn. 52,70,00,000 Total 11,60,82,46,166 Copies of the sanction letters were also furnished for perusal. It is noticed that all these loans were sanctioned to the assessee for the purpose of setting up the Vishnuprayag Hydro