JOINT COMMISSIONER OF INCOME TAX, SUBHASH ROAD DEHADUN vs. M/S TIMES SQUARE, SAHASTRADHARA ROAD

In the result, appeal of the Revenue is dismissed

CAPITAL A/C\n630849.81 CLOSING STOCK\n49702307.00\nHDB FINANCIAL SERVICES\n(AS CERTIFIED BY PARTNERS)\n22500000.00\nHDFC LTD\n16000000.00 CASH IN HAND\n10789-16.00\nAXIS BANK\n2103284.16\nIDBI BANK\n2427220.00\nHDFC BANK\n50000.00\nUNSECURED LOAN\n100000.00\nIAS PER ANNEXURE B)\n9950000.00 KOTAK MAHINDRA\n\nCURRENT LIABILITIES\nLOANS & ADVANCES\n& PROVISIONS:\n1748596.48 CHEQUES IN HAND\n2250000.00\nSUNDRY CREDITORS\n28522350.00

SAHKUMBARI ASSOCIATES,DEHRADUN vs. ACIT, CIRCLE-2, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Shri Anil Chaturvedi & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.261/Del/2018 िनधा"रणवष"/Assessment Year: 2014-15 बनाम Sahkumbari Associates, Acit Vs. C/O Matta Garg & Co., Circle-2, 15, Astley Hall, Dehradun. Dehradun, Uttarakhand. Pan No. Aagas1127F अपीलाथ" Appellant ""यथ"/Respondent

D E R PER C.N. PRASAD, J.M. This appeal is filed by the Assessee against the order of learned Commissioner of Income Tax (Appeals), Dehradun dated 12.12.2017 for the AY 2014-15. In the grounds of appeal the assessee challenged the order of the Ld. CIT(Appeals) in sustaining the disallowance of Rs.71

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

Appeal is partly allowed in above terms

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

d) "The determination of the character of land, according to the purpose for which it is meant or set apart and can be used, is a matter which ought to be determined on the facts of each particular case", (e) The fact that the land is assessed to the Land Revenue as agricultural land under the State Revenue

SHRI CHHOTEY LAL VERMA,DEHRADUN vs. DEPUTY COMMISSIONER OF INCOME-TAX, DEHRADUN

In the result, appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

D. R.; Date of Hearing 14.12.2022 Date of Pronouncement 31.01.2023 2 ITAs. 3396 & 3397/DDN/2015 Shri Chhotey Lal Verma, Dehradun. ORDER PER YOGESH KUMAR U.S., JM These two appeals are filed by the Assessee against two separate orders of the ld. Commissioner of Income Tax (Appeals), Dehradun [hereinafter referred to CIT (Appeals) both dated 26.03.2015 for assessment years

SHRI CHHOTEY LAL VERMA,DEHRADUN vs. DEPUTY COMMISSIONER OF INCOME-TAX, DEHRADUN

In the result, appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

D. R.; Date of Hearing 14.12.2022 Date of Pronouncement 31.01.2023 2 ITAs. 3396 & 3397/DDN/2015 Shri Chhotey Lal Verma, Dehradun. ORDER PER YOGESH KUMAR U.S., JM These two appeals are filed by the Assessee against two separate orders of the ld. Commissioner of Income Tax (Appeals), Dehradun [hereinafter referred to CIT (Appeals) both dated 26.03.2015 for assessment years

SHRI ADITYA VERMA,DEHRADUN vs. DEPUTY COMMISSIONER OF INCOME-TAX, DEHRADUN

In the result, appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

D. R.; Date of Hearing 14.12.2022 Date of Pronouncement 31 01.2023 ORDER PER YOGESH KUMAR U.S., JM These three appeals are filed by the assessee against three separate orders of the ld. Commissioner of Income Tax (Appeals), Dehradun [hereinafter referred to CIT (Appeals) both dated 26.03.2015 & 26.04.2013 for assessment years 2008-09 and 2009-10 respectively. 2. The assessee

SHRI ADITYA VERMA,DEHRADUN vs. DEPUTY COMMISSIONER OF INCOME-TAX, DEHRADUN

In the result, appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

D. R.; Date of Hearing 14.12.2022 Date of Pronouncement 31 01.2023 ORDER PER YOGESH KUMAR U.S., JM These three appeals are filed by the assessee against three separate orders of the ld. Commissioner of Income Tax (Appeals), Dehradun [hereinafter referred to CIT (Appeals) both dated 26.03.2015 & 26.04.2013 for assessment years 2008-09 and 2009-10 respectively. 2. The assessee

SHRI PURAN SINGH VERMA,DEHRADUN vs. DEPUTY COMMISSIONER OF INCOME-TAX, DEHRADUN

In the result, appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

D. R.; z Date of Hearing 14.12.2022 Date of Pronouncement 31.01.2023 2 ITAs. 3400 & 3401/DDN/2015 Puran Singh Verma, Dehradun. ORDER PER YOGESH KUMAR U.S., JM These two appeals are filed by the assessee against two separate orders of the ld. Commissioner of Income Tax (Appeals), Dehradun [hereinafter referred to CIT (Appeals) both dated 26.03.2015 for assessment years

SHRI PURAN SINGH VERMA,DEHRADUN vs. DEPUTY COMMISSIONER OF INCOME-TAX, DEHRADUN

In the result, appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

D. R.; z Date of Hearing 14.12.2022 Date of Pronouncement 31.01.2023 2 ITAs. 3400 & 3401/DDN/2015 Puran Singh Verma, Dehradun. ORDER PER YOGESH KUMAR U.S., JM These two appeals are filed by the assessee against two separate orders of the ld. Commissioner of Income Tax (Appeals), Dehradun [hereinafter referred to CIT (Appeals) both dated 26.03.2015 for assessment years

DR. VIRENDRA SWAROOP EDUCATIONAL FOUNDATION,KANPUR vs. ACIT, CENTRAL CIRCLE, DEHRADUN, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2023-24] Dr. Virendra Swaroop Vs Acit Educational Foundation Central Circle 15/96, Civil Lines, Kanpur Dehradun Uttar Pradesh-208001 Pan-Aaajd0224D Appellant Respondent Assessee By Shri Salil Kapoor, Adv. Shri Rajiv Sahni, Ca Shri Sumit Lal Chandanim, Adv. Shri Shivam Yadav, Adv. & Ms. Ananya Kapoor, Adv. Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 11.12.2025 Date Of Pronouncement 16.01.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 16.09.2025 By Ld. Pr. Commissioner Of Income Tax (Central), Kanpur [“Pcit”] Passed U/S 12(Ab)(4)(Ii) Of The Income Tax Act, 1961[“The Act”] Cancelling The Registration Granted U/S 12A Of The Act From Assessment Year 2023-24 & Onwards.

gains of the real estate business of sale, purchase and leasing activities can be termed as incidental to the attainment of trust's objectives and are in the nature of commercial activities carried out for purposes other than for the objects of the trust. Therefore, vide impugned order, ld. PCIT has cancelled the registration granted u/s 12A/12AA or 12AB

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

5. From Financial REC 1,14,00,00,000 Institutions 6. Foreign Currency Loan Power Finance Corp. 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

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

5. From Financial REC 1,14,00,00,000 Institutions 6. Foreign Currency Loan Power Finance Corp. 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

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

5. From Financial REC 1,14,00,00,000 Institutions 6. Foreign Currency Loan Power Finance Corp. 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

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

5. From Financial REC 1,14,00,00,000 Institutions 6. Foreign Currency Loan Power Finance Corp. 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

SHRI PRITPAL SINGH,DEHRADUN vs. THE ASSISTANT COMMISSIONER OF INCOME TAX , CIRCLE-2, DEHRADUN

In the result, the appeal of the Assessee is allowed

Bench: Sh. C. N. Prasad & Shri M. Balaganesh(Through Video Conferencing) Shri Pritpal Singh, Vs. Acit, 71, Guru Road, Circle-2, Dehradun Dehradun (Appellant) (Respondent) Pan: Ahkps3632F Assessee By : Shri Savyasachi Kumar Sahai, Adv Revenue By: Shri Amar Singh Rana, Sr. Dr Date Of Hearing 22/08/2023 Date Of Pronouncement 15/09/2023

D) It is humbly submitted that the ratio decidendi / judicial principles of the case law are required to be applied in the present case, and it is inconceivable that the fact situation shall always be identical. E) The case law cited clearly lays out the law that where the assessee had offered actual amount received on sale of property

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

d) Several bottom holes samples would be collected during wireline formation testing (MDT) in different wells in the block. The samples will be transferred from MDT sample chambers to specified bottles. e) Post that considering that said samples are waxy in nature, higher temperature would be maintained during the transport . The equipment / experts would be suitable to perform successful transfer

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

d) Several bottom holes samples would be collected during wireline formation testing (MDT) in different wells in the block. The samples will be transferred from MDT sample chambers to specified bottles. e) Post that considering that said samples are waxy in nature, higher temperature would be maintained during the transport . The equipment / experts would be suitable to perform successful transfer

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

d) Several bottom holes samples would be collected during wireline formation testing (MDT) in different wells in the block. The samples will be transferred from MDT sample chambers to specified bottles. e) Post that considering that said samples are waxy in nature, higher temperature would be maintained during the transport . The equipment / experts would be suitable to perform successful transfer