PURAN SINGH NEGI,HALDWANI vs. THE ASSIST COMMISSIONER OF INCOME TAX , NANITAL

In the result, the appeal of the assessee is allowed for statistical purpose

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.I.T.A. No. 33/Ddn/2020 (A.Y 2016-17)

gains of business or profession". Further, section 56 of the Income-tax Act has also been amended to provide that any compensation received or receivable by any person, whether in the nature of revenue or capital, in connection with the 4 Puran Singh Negi termination or the modification of the terms and conditions of any contract relating to his employment

LATE SHRI CHANDRA PRAKASH CHAUDHARY THROUGH LEAGAL HEIR MRS. ANJU CHAUDHARY,NEW DELHI vs. DCIT, CIRCLE- 1 , DEHRADUN

Capital Gain Rs. 26,383/- Income from other sources Rs. 12,388/- Taxable Income Rs. 35,81,330/- 6. Aggrieved by the assessment order dated 26/06/2014 passed u/s 143(3)/153Ac(1)(b)/254 of the Act, the assessee preferred an Appeal before the Ld. CIT(A), the Ld. CIT(A) vide order dated 28/03/2017 treated the classification of losses

LATE SHRI CHANDRA PRAKASH CHAUDHARY THROUGH LEAGAL HEIR MRS. ANJU CHAUDHARY,NEW DELHI vs. DCIT, CIRCLE- 1 , DEHRADUN

Capital Gain Rs. 26,383/- Income from other sources Rs. 12,388/- Taxable Income Rs. 35,81,330/- 6. Aggrieved by the assessment order dated 26/06/2014 passed u/s 143(3)/153Ac(1)(b)/254 of the Act, the assessee preferred an Appeal before the Ld. CIT(A), the Ld. CIT(A) vide order dated 28/03/2017 treated the classification of losses

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

capital gains, and other items of income). 2. The Agreement shall also apply to any identical or substantially similar taxes which are imposed by either Contracting State after the date of signature of the present Agreement in addition to, or in place of, the taxes referred to in paragraph 1 of this Article. 3. In this Agreement, the term "Indian

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

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 u/s 132 of the Act at the business

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

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 u/s 132 of the Act at the business

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

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 u/s 132 of the Act at the business

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

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 u/s 132 of the Act at the business

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

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 u/s 132 of the Act at the business

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

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 u/s 132 of the Act at the business

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

capital in nature and depreciation and depletion on capitalised portion is subsequently disallowed, the amount capitalised by the appellant should be allowed as deduction under section 37(1) of the Act in the relevant assessment year. 53. The ld. CIT DR has no objection for the above issue to be set aside to ld. AO/TPO. 54. After hearing both

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

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

capital assets to the extent of 90% of gross revenue. (ix) Whether the CIT (A) has erred in not appreciating the fact that the amount received by the assessee on account of equipment lost in hole’ is infact the reimbursement of expenses and hence includible in the gross revenue for the purpose of computation of profits as per the provisions

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

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

capital assets to the extent of 90% of gross revenue. (ix) Whether the CIT (A) has erred in not appreciating the fact that the amount received by the assessee on account of equipment lost in hole’ is infact the reimbursement of expenses and hence includible in the gross revenue for the purpose of computation of profits as per the provisions

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

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

capital assets to the extent of 90% of gross revenue. (ix) Whether the CIT (A) has erred in not appreciating the fact that the amount received by the assessee on account of equipment lost in hole’ is infact the reimbursement of expenses and hence includible in the gross revenue for the purpose of computation of profits as per the provisions

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

gains from such business chargeable to tax is to be calculated at a sum equal to 10% of the aggregate of the amounts paid or payable to such non-resident assessee as mentioned in Sub-section (2). On the other hand, Section 44D contemplates that if the income of a foreign company with which the government or an Indian concern

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

41. 2796 Training in Safety Rating System and assistance in development and audit of Safety Management System. 42. 1239 To develop technical specification for 3D Seismic API modules of work and to prepare bid packages. 43. 1527 Supply supervision and installation of software which is used for analysis of flow rate of mineral oil to determine reservoir conditions

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

41. 2796 Training in Safety Rating System and assistance in development and audit of Safety Management System. 42. 1239 To develop technical specification for 3D Seismic API modules of work and to prepare bid packages. 43. 1527 Supply supervision and installation of software which is used for analysis of flow rate of mineral oil to determine reservoir conditions

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

41. 2796 Training in Safety Rating System and assistance in development and audit of Safety Management System. 42. 1239 To develop technical specification for 3D Seismic API modules of work and to prepare bid packages. 43. 1527 Supply supervision and installation of software which is used for analysis of flow rate of mineral oil to determine reservoir conditions