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

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

4 of 16 ITA No.4258 & 4259/Del/2018 Late Sh. Chandra prakash Chaudhary 5. After the remand from the Tribunal, the assessment order came to be passed on 26/06/2014 by making additions as under:- House Property income Rs. 1,37,980/- Business Income Rs. 34,04,580/- Short Term Capital Gain Rs. 26,383/- Income from other sources Rs. 12,388/- Taxable

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

4 of 16 ITA No.4258 & 4259/Del/2018 Late Sh. Chandra prakash Chaudhary 5. After the remand from the Tribunal, the assessment order came to be passed on 26/06/2014 by making additions as under:- House Property income Rs. 1,37,980/- Business Income Rs. 34,04,580/- Short Term Capital Gain Rs. 26,383/- Income from other sources Rs. 12,388/- Taxable

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

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

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

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

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

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

4. 1722 Furnishing supervisory staff with expertise in operation and management of Drilling unit. 5. 729 Capping including subduing of well, fire fighting. 6. 738 Capping including subduing of well, fire fighting. 7. 1528 Analysis of data to prepare job design, procedure for execution and details regarding monitoring. 8. 1532 Study for selection of enhanced Oil Recovery processes and conceptual

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

4. 1722 Furnishing supervisory staff with expertise in operation and management of Drilling unit. 5. 729 Capping including subduing of well, fire fighting. 6. 738 Capping including subduing of well, fire fighting. 7. 1528 Analysis of data to prepare job design, procedure for execution and details regarding monitoring. 8. 1532 Study for selection of enhanced Oil Recovery processes and conceptual

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

4. 1722 Furnishing supervisory staff with expertise in operation and management of Drilling unit. 5. 729 Capping including subduing of well, fire fighting. 6. 738 Capping including subduing of well, fire fighting. 7. 1528 Analysis of data to prepare job design, procedure for execution and details regarding monitoring. 8. 1532 Study for selection of enhanced Oil Recovery processes and conceptual

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

4. 1722 Furnishing supervisory staff with expertise in operation and management of Drilling unit. 5. 729 Capping including subduing of well, fire fighting. 6. 738 Capping including subduing of well, fire fighting. 7. 1528 Analysis of data to prepare job design, procedure for execution and details regarding monitoring. 8. 1532 Study for selection of enhanced Oil Recovery processes and conceptual

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