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

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

v) Whether the CIT (A) has erred in overlooking that the assessee was not engaged in any construction, assembly, mining or like project and had only provided ancillary services, and thus did not fall in the exclusion clause of section 9(1)(vii) of the Act, in distinction to the lead case of Foramer inter alia covered

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

v . Corporation Bank Limited (174 ITR 616). 52 . In view of the above binding precedents, the AO ought to be directed to accept the opening WDV of assets as submitted by the appellant in the schedule to computation of income which is arrived from the closing WDV of fixed assets of previous year. Accordingly , the AO be directed to delete

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

36. The Tribunal in appellant's own case for the assessment years 2011-12 (ITA No. 1478/Del/2017), 2012- 13 (ITA No. 6791/Del./2017), 2013-14 (ITA No. 7476/Del/2018) and 2014-15 (ITA No. 7477/Del/2018), 2016- 17 (ITA No.7/DDN/2019) and 2017-18 (ITA No.5/DDN/2022) allowed these expenses and hence we decline to deviate from the earlier orders of the Tribunal. Depreciation

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

36. The Tribunal in appellant's own case for the assessment years 2011-12 (ITA No. 1478/Del/2017), 2012- 13 (ITA No. 6791/Del./2017), 2013-14 (ITA No. 7476/Del/2018) and 2014-15 (ITA No. 7477/Del/2018), 2016- 17 (ITA No.7/DDN/2019) and 2017-18 (ITA No.5/DDN/2022) allowed these expenses and hence we decline to deviate from the earlier orders of the Tribunal. Depreciation