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

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

32,902/- in the order passed u/s 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

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

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

depreciation and depletion on capitalised portion is subsequently disallowed, the amount capitalised by the appellant should be allowed as deduction under section 37(1) of the Act in the relevant assessment year . 53 . The ld . CIT DR has no objection for the above issue to be set aside to ld . AO/TPO. 54 . After hearing both the sides and considering

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

32. The similar issue has been adjudicated for the AY 2010-11-ITA No. 1170/Del/2015, AY 2011-12- ITA No.1478/Del/2017, AY 2012-13- ITA No.6791/Del/2017, AY 2013-14- ITA No.7476/Del/2018, AY 2014-15- ITA No.7477/Del/2018, AY 2016-17- ITA No.7/DDN/2019 and AY 2017-18- ITA No.5/DDN/2022, hence, we hereby abide by the decision of the earlier orders. Disallowance of expenditure

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

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

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

32. The similar issue has been adjudicated for the AY 2010-11-ITA No. 1170/Del/2015, AY 2011-12- ITA No.1478/Del/2017, AY 2012-13- ITA No.6791/Del/2017, AY 2013-14- ITA No.7476/Del/2018, AY 2014-15- ITA No.7477/Del/2018, AY 2016-17- ITA No.7/DDN/2019 and AY 2017-18- ITA No.5/DDN/2022, hence, we hereby abide by the decision of the earlier orders. Disallowance of expenditure

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

In the result, appeal of the assessee in ITA No

1) That the assessee had a PE in India; 2) That the contract under consideration was a composite contract; and 3) That the entire contract revenues (both inside India and outside India) were attributable to the alleged PE in India and chargeable to tax in India on income computed @25% deemed profit rate. 4. The income has been computed

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

In the result, appeal of the assessee in ITA No

1) That the assessee had a PE in India; 2) That the contract under consideration was a composite contract; and 3) That the entire contract revenues (both inside India and outside India) were attributable to the alleged PE in India and chargeable to tax in India on income computed @25% deemed profit rate. 4. The income has been computed