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

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

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

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

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

In the result, appeal of the assessee in ITA No

4. The income has been computed by the ld AO after holding „inside India revenue‟ of Rs. 60,89,46,384/- and “outside India revenue” of Rs. 643,19,18,042/-, being income attributable to „inside India Operations‟ and to the Indian Permanent Establishment (PE) and income computed at profit rate of 25% thereof. While doing

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

In the result, appeal of the assessee in ITA No

4. The income has been computed by the ld AO after holding „inside India revenue‟ of Rs. 60,89,46,384/- and “outside India revenue” of Rs. 643,19,18,042/-, being income attributable to „inside India Operations‟ and to the Indian Permanent Establishment (PE) and income computed at profit rate of 25% thereof. While doing