B G EXPLORATION & PRODUCTION INDIA LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME, DDIT/ ADIT (INTERNATIONAL TAXATION), CIRCLE-1, DEHRADUN, DEHRADUN, UTTARAKHAND

In the result, both the appeals of the assessee are allowed

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

37,84,218 incurred on non-producing PSCs. 9.2 The learned AO / DRP erred in not appreciating the fact that set off of expenditure of non- producing PSC against the income of PSC in which commercial production has been commenced is in accordance with the provisions of the Act and provisions of PSC. 9.3 The learned AO / DRP erred

MB PETROLEUM SERVICES LLC,MUMBAI vs. DDIT, DEHRADUN

In the result, the appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Saktijit Dey & Shri M. Balaganeshmb Petroleum Services Llc, Vs. Ddit, Kirtane & Pandit, H-16, Circle-1, Saraswati Colony, Sitaldevi International Taxation, Temple Road, Mahim, Dehradun Mumbai (Appellant) (Respondent) Pan: Aaecm2604H

depreciation to the Appellant under section 32 of the Act in accordance with law.” 4. We have heard the rival submissions and perused the materials available on record. At the outset, we find that the additional ground of appeal raised by the assessee is a legal issue and does not require verification of any facts. Hence, it is admitted

M.B. PETROLEUM SERVICES LLC,NEW DELHI vs. DCIT (INTERNATIONAL TAXATION), DEHRADUN

In the result, the appeal of the assessee is allowed

37(1) of the Act 9 ITA No.6608/Del./2016 or section 40(a)(i) of the Act would not survive. Similarly, the adjudication of additional ground for claim of income tax depreciation u/s 32 of the Act also would become academic. In our considered opinion, even though the assessee has offered more income in its return than the income

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

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

depreciation on 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

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

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

depreciation on 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

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

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

depreciation on 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

METRO FROZEN FRUIT & VEGETABLES PVT. LTD.,ROORKEE vs. DCIT, CIRCLE, HARIDWAR

In the result, the appeal of the assessee is party allowed

Bench: Shri R.K. Panda & Shri N. K. Choudhry[Assessment Year: 2009-10] Metro Frozen Fruits & Dcit, Vegetables Pvt. Ltd. Circle Haridwar, Plot No.22, Rajpur, Vs Uttarakhan Bhagwanpur, Roorkee, Uttrakhand Pan-Aaecm4521F Assessee Revenue Assessee By Sh. Piyush Kuchhal, Fca Revenue By Ms. Poonam Sharma Cit-Dr Date Of Hearing 23.02.2022 Date Of Pronouncement 08.03.2022 Order Per R.K. Panda, Am, This Appeal Filed By The Assessee Is Directed Against The Order Dated 24.01.2019 Of The Learned Cit(A), Dehradun, Relating To Assessment Year 2009-10. 2. The Grounds Raised By The Assessee Are As Under:-

10% 1,25,57,597/- 18,75,357/- 1,39,468/- 0 14,50,269/- 1,31,22,153/- Equipments Others 34,74,877/- 30,47,272/- 4,27,605/- 4,27,605/- 0 0 0 Total 3,40,94,290/- 37

SANJAY BANSAL,DEHRADUN vs. DCIT CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Sh. Anil Chaturvedi & Sh. Challa Nagendra Prasad

10. That the CIT(A) grossly erred in law and on facts in assuming jurisdiction vide issuance of consolidated/ combined notice of enhancement for all the concerned assessment years. The enhancement made consequent to issue of illegal notice is thus liable to be deleted. 11. That the CIT(A) has enhanced the income of the assessee without examining the books

SANJAY BANSAL,DEHRADUN vs. DCIT CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Sh. Anil Chaturvedi & Sh. Challa Nagendra Prasad

10. That the CIT(A) grossly erred in law and on facts in assuming jurisdiction vide issuance of consolidated/ combined notice of enhancement for all the concerned assessment years. The enhancement made consequent to issue of illegal notice is thus liable to be deleted. 11. That the CIT(A) has enhanced the income of the assessee without examining the books

SANJAY BANSAL,NEW DELHI vs. DCIT CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Sh. Anil Chaturvedi & Sh. Challa Nagendra Prasad

10. That the CIT(A) grossly erred in law and on facts in assuming jurisdiction vide issuance of consolidated/ combined notice of enhancement for all the concerned assessment years. The enhancement made consequent to issue of illegal notice is thus liable to be deleted. 11. That the CIT(A) has enhanced the income of the assessee without examining the books

SANJAY BANSAL,DEHRADUN vs. DCIT CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Sh. Anil Chaturvedi & Sh. Challa Nagendra Prasad

10. That the CIT(A) grossly erred in law and on facts in assuming jurisdiction vide issuance of consolidated/ combined notice of enhancement for all the concerned assessment years. The enhancement made consequent to issue of illegal notice is thus liable to be deleted. 11. That the CIT(A) has enhanced the income of the assessee without examining the books