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

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

143(3)/144C(3)(b) of the Income Tax Act, 1961 (in short “the Act”), appeal-wise; respectively. 2. Heard both the parties at length. Case files perused. We proceed assessment year wise for the sake of convenience and brevity. Assessment Year 2013-14: Assessee’s appeal ITA No. 6026/Del/2017 and Cross appeal ITA No. 6171/Del/2017 3. Learned counsel submits

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

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

143(3)/144C(3)(b) of the Income Tax Act, 1961 (in short “the Act”), appeal-wise; respectively. 2. Heard both the parties at length. Case files perused. We proceed assessment year wise for the sake of convenience and brevity. Assessment Year 2013-14: Assessee’s appeal ITA No. 6026/Del/2017 and Cross appeal ITA No. 6171/Del/2017 3. Learned counsel submits

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

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

143(3)/144C(3)(b) of the Income Tax Act, 1961 (in short “the Act”), appeal-wise; respectively. 2. Heard both the parties at length. Case files perused. We proceed assessment year wise for the sake of convenience and brevity. Assessment Year 2013-14: Assessee’s appeal ITA No. 6026/Del/2017 and Cross appeal ITA No. 6171/Del/2017 3. Learned counsel submits

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

143(3)/144C of the Income Tax Act (''the Act''). 2. In law and on facts and circumstances of the case, Ld. AO erred in not affording a proper opportunity to the Assessee of being heard. The Assessment order passed is against the principle of natural justice. 3. Without prejudice to above and in law and in facts and circumstances

DCIT (INTERNATIONAL TAXATION), DEHRADUN vs. M/S. SAMSUNG HEAVY INDUSTRIES CO. LTD., GURGAON

In the result, appeal of the assessee in ITA No

143(3)/144C of the Act, assessed the total income of the assessee at Rs. 1,76,02,16,110 (as against returned loss of Rs. 89,73,23,135/-). While doing so, the learned AO held as under: Samsung Heavy Industries Co. Ltd. vs. DCIT (Int. tax.) 1) That the assessee had a PE in India; 2) That

SAMSUNG HEAVY INDUSTRIES CO. LTD.,GURGAON vs. DCIT (INTERNATIONAL TAXATION), DEHRADUN

In the result, appeal of the assessee in ITA No

143(3)/144C of the Act, assessed the total income of the assessee at Rs. 1,76,02,16,110 (as against returned loss of Rs. 89,73,23,135/-). While doing so, the learned AO held as under: Samsung Heavy Industries Co. Ltd. vs. DCIT (Int. tax.) 1) That the assessee had a PE in India; 2) That