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5 results for “capital gains”+ Section 36(1)(iii)clear

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Key Topics

Section 9(1)(vii)15Section 44B12Section 808Section 143(3)7Section 80I6Section 9(1)(i)3Section 44D3Section 144C2Transfer Pricing2

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

ITA 6026/DEL/2017[2013-14]Status: DisposedITAT Dehradun07 May 2025AY 2013-14

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

For Appellant: Sh. Salil Kapoor, Sh. S. LalchandaniFor Respondent: Sh. Mithun Shete, Sr. DR
Section 143(3)Section 44BSection 44DSection 9(1)(i)Section 9(1)(vii)

iii) Whether on the facts and in the circumstances of the case and in law, the CIT (A) has erred in failing to note that the Memorandum to Finance Bill 2010 makes it clear that any service which falls within the ambit of 44DA, even if it is in connection with prospecting for., or extraction or production of mineral oils

Deduction2
Comparables/TP2

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

ITA 6171/DEL/2017[2013-14]Status: DisposedITAT Dehradun07 May 2025AY 2013-14

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

For Appellant: Sh. Salil Kapoor, Sh. S. LalchandaniFor Respondent: Sh. Mithun Shete, Sr. DR
Section 143(3)Section 44BSection 44DSection 9(1)(i)Section 9(1)(vii)

iii) Whether on the facts and in the circumstances of the case and in law, the CIT (A) has erred in failing to note that the Memorandum to Finance Bill 2010 makes it clear that any service which falls within the ambit of 44DA, even if it is in connection with prospecting for., or extraction or production of mineral oils

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

ITA 6714/DEL/2017[2014-15]Status: DisposedITAT Dehradun07 May 2025AY 2014-15

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

For Appellant: Sh. Salil Kapoor, Sh. S. LalchandaniFor Respondent: Sh. Mithun Shete, Sr. DR
Section 143(3)Section 44BSection 44DSection 9(1)(i)Section 9(1)(vii)

iii) Whether on the facts and in the circumstances of the case and in law, the CIT (A) has erred in failing to note that the Memorandum to Finance Bill 2010 makes it clear that any service which falls within the ambit of 44DA, even if it is in connection with prospecting for., or extraction or production of mineral oils

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

ITA 24/DDN/2022[2018-19]Status: DisposedITAT Dehradun23 May 2023AY 2018-19

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

For Appellant: Sh. Nageshwar Rao, AdvFor Respondent: Sh. Pramod Verma, CIT DR
Section 143(3)Section 144CSection 80Section 80ISection 92BSection 92C

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

ITA 3/DDN/2022[2017-18]Status: DisposedITAT Dehradun23 May 2023AY 2017-18

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

For Appellant: Sh. Nageshwar Rao, AdvFor Respondent: Sh. Pramod Verma, CIT DR
Section 143(3)Section 144CSection 80Section 80ISection 92BSection 92C

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