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

4: Erroneously disregarded the decision of Hon'ble ITAT in AY 2011-12 to AY 2014-15 and AY 2016-17 and directions of the Hon'ble DRP for AY 2009-10 and AY 2010-11 4.1 The learned TPO / AO / DRP erred in disregarding the decision of Hon'ble ITAT

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 of the assessee is partly allowed

Bench: Shri R.K. Panda & Shri V.P. Raoassessment Years: 2016-17

37,656. Ground No. 15: Short grant of interest under section 244A 15.1 The learned AO erred in fact and in law, in granting short interest under section 244A of the Act. Ground No. 16: General 16.1 The Appellant submits that the AO, TPO and DRP have erred in arriving various unwarranted and erroneous conclusions unsupported by any relevant material

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

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

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

4: Without prejudice that TNMM should be selected, learned TPO / AO / DRP applied CUP method in an erroneous manner 4.1 Without prejudice that TNMM should be selected as the most appropriate method for benchmarking the transactions pertaining to intra-group services, the learned TPO / AO / DRP have erroneously selected CUP method and have applied the same in an erroneous manner

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

4: Without prejudice that TNMM should be selected, learned TPO / AO / DRP applied CUP method in an erroneous manner 4.1 Without prejudice that TNMM should be selected as the most appropriate method for benchmarking the transactions pertaining to intra-group services, the learned TPO / AO / DRP have erroneously selected CUP method and have applied the same in an erroneous manner

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

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:-

37,38,115/- 4,67,652/- 30,47,272/- 3,52,52,785/- 44,67,084/- 3,07,85,701/- . From the above two tables it is clear that the WDV of machinery block as on 31.03.2008 was Rs.1,18,73,198/- but WDV of machinery block as on 01.04.2008 has been shown by the assessee

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

In the result, the appeal of the assessee is allowed

depreciation and amortization of Rs. 49,75,184/-. 8. Without prejudice to above and in law and circumstances of the case, the Ld. AO erred in disallowing expense of Rs.11,660/- on the ground that they cannot be verified. 9. Without prejudice to above and in law and circumstances of the case, the ld. AO erred in disallowing the expense

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

4. That no valid search is conducted on the assessee, hence the notice issued u/s 153 A of the Act is illegal, bad in law and without jurisdiction. Thus, the order passed u/s 153A r.w.s 143(3) of the Act is also illegal bad in law and without jurisdiction. 5. That the assessment order passed without valid approval U/s 153D

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

4. That no valid search is conducted on the assessee, hence the notice issued u/s 153 A of the Act is illegal, bad in law and without jurisdiction. Thus, the order passed u/s 153A r.w.s 143(3) of the Act is also illegal bad in law and without jurisdiction. 5. That the assessment order passed without valid approval U/s 153D

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

4. That no valid search is conducted on the assessee, hence the notice issued u/s 153 A of the Act is illegal, bad in law and without jurisdiction. Thus, the order passed u/s 153A r.w.s 143(3) of the Act is also illegal bad in law and without jurisdiction. 5. That the assessment order passed without valid approval U/s 153D

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

4. That no valid search is conducted on the assessee, hence the notice issued u/s 153 A of the Act is illegal, bad in law and without jurisdiction. Thus, the order passed u/s 153A r.w.s 143(3) of the Act is also illegal bad in law and without jurisdiction. 5. That the assessment order passed without valid approval U/s 153D