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

depreciation claim on Global IT & T expenditure was allowable as held by the Hon’ble ITAT in Appellant’s own case for AYs 2010-11 to 2014- 15. 11.3 The learned AO / DRP erred in not appreciating that this difference is on account of difference in opening written down value of assets on first day of the captioned assessment year

DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE), DEHRADUN, DEHRADUN vs. STONEFIELD CONSTRUCTION, DEHRADUN, DEHRADUN

In the result, appeal of the Revenue is partly allowed

45,72,020/- which is less than the threshold limit of INR 50.00 as provided in section 194Q of the Act, therefore, the provisions of this section are not applicable. A clarification issued by the CBDT dated 13.06.2021 vide Circular No.13/2021 was also relied upon. Ld. CIT(A) after considering these facts and the circular of CBDT has deleted

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

In the result, appeal of the assessee in ITA No

45,563/- was 14.56% of the total revenue of the for inside India work which was Rs. crore. The invoices raised by the assessee for inside India activity were to the tune of Rs. 3,25,82,569/- which have been listed at para 5 of the assessment order. It was further noticed out of total expenses incurred

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

In the result, appeal of the assessee in ITA No

45,563/- was 14.56% of the total revenue of the for inside India work which was Rs. crore. The invoices raised by the assessee for inside India activity were to the tune of Rs. 3,25,82,569/- which have been listed at para 5 of the assessment order. It was further noticed out of total expenses incurred