M/S. JAIPRAKASH POWER VENTURES LTD.,,H.P. vs. DCIT, DEHRADUN

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 Vs. Dcit, M/S, Jaiprakash Power Ventures Ltd., Circle-2, 113, Rajpur Road, Dehradun Dehradun Pan: Aaacj5463 (Appellant) (Respondent) With Assessment Year: 2008-09 Vs. M/S, Dcit, Jaiprakash Power Circle-2, Ventures Ltd., Dehradun Juit, Complex, Waknaghat, Post Office- Dumehar Bani, Kandaghat, Distt. Solan, Himachal Pradesh Pan: Aaacj5463 (Appellant) (Respondent) Assessee By Sh. Anil K. Chopra, Ca Sh. Sanjiv Choudhary, Ca Sh. V.K. Garg, Adv. Department By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 20.03.2025 Date Of Pronouncement 23.05.2025

90,42,19,404/- against interest income of Rs. 2,43,02,346/- for computing the profits and gains of business and eligible deduction u/s 801A of the appellant. As interest expenditure much exceeds the interest income, no interest amount was to be reduced in computing eligible deduction u/s 801A. 3. That the Ld. CIT(A) has erred

M/S. JAIPRAKASH POWER VENTURES LTD.,DEHRADUN vs. DCIT, DEHRADUN

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 Vs. Dcit, M/S, Jaiprakash Power Ventures Ltd., Circle-2, 113, Rajpur Road, Dehradun Dehradun Pan: Aaacj5463 (Appellant) (Respondent) With Assessment Year: 2008-09 Vs. M/S, Dcit, Jaiprakash Power Circle-2, Ventures Ltd., Dehradun Juit, Complex, Waknaghat, Post Office- Dumehar Bani, Kandaghat, Distt. Solan, Himachal Pradesh Pan: Aaacj5463 (Appellant) (Respondent) Assessee By Sh. Anil K. Chopra, Ca Sh. Sanjiv Choudhary, Ca Sh. V.K. Garg, Adv. Department By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 20.03.2025 Date Of Pronouncement 23.05.2025

90,42,19,404/- against interest income of Rs. 2,43,02,346/- for computing the profits and gains of business and eligible deduction u/s 801A of the appellant. As interest expenditure much exceeds the interest income, no interest amount was to be reduced in computing eligible deduction u/s 801A. 3. That the Ld. CIT(A) has erred

M/S. JAIPRAKASH POWER VENTURES LTD.,DEHRADUN vs. DCIT, DEHRADUN

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 Vs. Dcit, M/S, Jaiprakash Power Ventures Ltd., Circle-2, 113, Rajpur Road, Dehradun Dehradun Pan: Aaacj5463 (Appellant) (Respondent) With Assessment Year: 2008-09 Vs. M/S, Dcit, Jaiprakash Power Circle-2, Ventures Ltd., Dehradun Juit, Complex, Waknaghat, Post Office- Dumehar Bani, Kandaghat, Distt. Solan, Himachal Pradesh Pan: Aaacj5463 (Appellant) (Respondent) Assessee By Sh. Anil K. Chopra, Ca Sh. Sanjiv Choudhary, Ca Sh. V.K. Garg, Adv. Department By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 20.03.2025 Date Of Pronouncement 23.05.2025

90,42,19,404/- against interest income of Rs. 2,43,02,346/- for computing the profits and gains of business and eligible deduction u/s 801A of the appellant. As interest expenditure much exceeds the interest income, no interest amount was to be reduced in computing eligible deduction u/s 801A. 3. That the Ld. CIT(A) has erred

DCIT, DEHRADUN vs. M/S JAI PRAKASH POWER VENTURE LTD., H.P.

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 Vs. Dcit, M/S, Jaiprakash Power Ventures Ltd., Circle-2, 113, Rajpur Road, Dehradun Dehradun Pan: Aaacj5463 (Appellant) (Respondent) With Assessment Year: 2008-09 Vs. M/S, Dcit, Jaiprakash Power Circle-2, Ventures Ltd., Dehradun Juit, Complex, Waknaghat, Post Office- Dumehar Bani, Kandaghat, Distt. Solan, Himachal Pradesh Pan: Aaacj5463 (Appellant) (Respondent) Assessee By Sh. Anil K. Chopra, Ca Sh. Sanjiv Choudhary, Ca Sh. V.K. Garg, Adv. Department By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 20.03.2025 Date Of Pronouncement 23.05.2025

90,42,19,404/- against interest income of Rs. 2,43,02,346/- for computing the profits and gains of business and eligible deduction u/s 801A of the appellant. As interest expenditure much exceeds the interest income, no interest amount was to be reduced in computing eligible deduction u/s 801A. 3. That the Ld. CIT(A) has erred

MRS. DHOOMI DEVI,CHAMOLI vs. ITO, W-1(4)4, SRINAGAR, CHAMOLI

In the result, appeal of the assessee is partly allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2022-23] Mrs. Dhoomi Devi Vs Ito C/O-Hotel Udai Palace Near . Ward-1(4)4 Narsingh Temple Srignagar, Chamoli Joshimath Chamoli, Uttarakhand-246174 Uttarakhand-246443 Pan-Adkpd6984B Appellant Respondent Assessee By Shri Tarandeep Singh, Adv. Revenue By Shri A.S. Rana, Sr. Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 13.02.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 08.08.2024 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Nfac/2021-22/10329482 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 05.03.2024 Passed U/S 143(3) R.W.S. 144B Of The Act Pertaining To Assessment Year 2022-23. 2. Brief Facts Of The Case Are That Assessee Is An Individual & The Case Was Selected For Scrutiny Under Cass For Reason I.E. “Large Investment In Immovable Property As Compared To The Total Income”. The Ao Than Passed The Assessment Order U/S 143(3) R.W.S. 144B On 05.03.2024 At A Total Income Of Inr 2,70,31,224/- As Against The Total Income Declared At Inr 29,45,000/- In The Return Of Income Filed By The Assessee.

section 54F(1) are satisfied in the present case and therefore the appellant is eligible to claim deduction u/s 54F of Rs. 1,90,86,224/- 4.1 That on facts and in law the AO/CIT(A) have erred in not appreciating that following properties inherited by the appellant are not a "residential house as they are commercial properties

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

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

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

In the result, appeal of the assessee is partly allowed

90 taxmann.com 365/253\nTaxman 401/410 ITR 244 (SC)\n➤ Delhi bench of ITAT in the case of Brahamputra Capital & Financial\nServices Ltd. v. ITO [2009] 119 ITD 266 (Delhi) have held that there\nwas uncertainty regarding ultimate collection of interest hence\nassessee was justified in not showing the notional interest income\nwhich did not actually materialized during the year under