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6 results for “capital gains”+ Section 71clear

Sorted by relevance

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Key Topics

Section 44B16Section 9(1)(vii)8Section 143(3)6Section 271(1)(c)6Section 50C4Permanent Establishment4Business Income4Double Taxation/DTAA4Penalty

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

In the result, the appeal of the Assessee is allowed

ITA 189/DDN/2019[2014-2015]Status: DisposedITAT Dehradun15 Sept 2023AY 2014-2015

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

For Appellant: Shri Savyasachi Kumar Sahai, AdvFor Respondent: Shri Amar Singh Rana, Sr. DR
Section 271(1)(c)Section 50CSection 56(2)(vii)

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 O R D E R PER M. BALAGANESH, A. M.: The appeal in ITA No.189/DDN/2019 arises out of the order of 1. the Commissioner of Income

2
Addition to Income2

M/S THDC INDIA LIMITED, RISHIKESH,RISHIKESH vs. PCIT, DEHRADUN, DEHRADUN

In the result, appeal of the assessee is partly allowed

ITA 69/DDN/2024[2020-21]Status: DisposedITAT Dehradun24 Dec 2025AY 2020-21
Section 142(1)Section 143(2)Section 143(3)Section 234ASection 250Section 251(1)(a)Section 270ASection 80

gain is\nto be allowed as eligible for deduction u/s 80 IA of the Act. With these\ndirections, Ground of appeal No.2 raised by the assessee is partly\nallowed.\n15. Ground of appeal Nos. 3 & 4 raised by the assessee are with\nrespect to the addition on account of late payment surcharge (LPSC)\nfrom debtors as well as enhancement made

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

ITA 5223/DEL/2018[2015-16]Status: DisposedITAT Dehradun15 Sept 2023AY 2015-16

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

For Appellant: Shri P. J. Pardiwalla, Sr. AdvFor Respondent: Shri Mayank Kumar, JCIT, DR
Section 143(3)Section 44BSection 9(1)(vii)

71,88,592/-. However, with regard to the contracts mentioned in Serial Numbers 216 to 231, the ld. AO observed that the said services to be taxed as fees for technical services u/s 9(1)(vii) of the Act and accordingly the provisions of section 44DA of the Act on net income basis would have to be applied

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

ITA 5305/DEL/2018[2015-16]Status: DisposedITAT Dehradun15 Sept 2023AY 2015-16

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

For Appellant: Shri P. J. Pardiwalla, Sr. AdvFor Respondent: Shri Mayank Kumar, JCIT, DR
Section 143(3)Section 44BSection 9(1)(vii)

71,88,592/-. However, with regard to the contracts mentioned in Serial Numbers 216 to 231, the ld. AO observed that the said services to be taxed as fees for technical services u/s 9(1)(vii) of the Act and accordingly the provisions of section 44DA of the Act on net income basis would have to be applied

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

ITA 6126/DEL/2017[2013-14]Status: DisposedITAT Dehradun15 Sept 2023AY 2013-14

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

For Appellant: Shri P. J. Pardiwalla, Sr. AdvFor Respondent: Shri Mayank Kumar, JCIT, DR
Section 143(3)Section 44BSection 9(1)(vii)

71,88,592/-. However, with regard to the contracts mentioned in Serial Numbers 216 to 231, the ld. AO observed that the said services to be taxed as fees for technical services u/s 9(1)(vii) of the Act and accordingly the provisions of section 44DA of the Act on net income basis would have to be applied

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

ITA 6173/DEL/2017[2014-15]Status: DisposedITAT Dehradun15 Sept 2023AY 2014-15

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

For Appellant: Shri P. J. Pardiwalla, Sr. AdvFor Respondent: Shri Mayank Kumar, JCIT, DR
Section 143(3)Section 44BSection 9(1)(vii)

71,88,592/-. However, with regard to the contracts mentioned in Serial Numbers 216 to 231, the ld. AO observed that the said services to be taxed as fees for technical services u/s 9(1)(vii) of the Act and accordingly the provisions of section 44DA of the Act on net income basis would have to be applied