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

SMT. KUSUM KUJWAL,NAINITAL vs. PCIT, BAIREILLY

Appeal is dismissed in above terms

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

Capital Gain and business profit as well, hence the order is erroneous and prejudicial to the interest of revenue. 7. Following judicial pronouncements are relevant to the facts of the case discussed and hence relied upon while adjudicating this case: (1) Hon’ble jurisdictional High Court of Allahabad in the case of Meerut Roller Flour Mills

IMSI (INDIA) PVT. LTD.,DEHRADUN vs. JCIT, DEHRADUN

In the result, all the three appeals filed by the assessee in ITA

Bench: Shri N.K. Billaiya & Ms. Suchitra Kamble

gains derived by an undertaking or an enterprise from any business of manufacturing or production of any article or thing not being article or thing specified in Thirteenth Schedule or commenced any operation specified in Fourteenth Schedule and undertakes substantial expansion during the period beginning on the 7 th day of January, 2003 and ending before 1