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

In the result, appeal of the assessee in ITA No

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 by the ld AO after holding „inside India revenue

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

In the result, appeal of the assessee in ITA No

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 by the ld AO after holding „inside India revenue

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

section 271(1)(c) of the Act. 16.3 The Appellant submits that each grounds of appeal are without prejudice to one another 16.4 The Appellant craves leave to add, alter, amend, substitute and / or modify in any manner whatsoever all or any of the foregoing grounds of objections at or before the hearing ofthe appeal.” 2. Ground

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

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, AY 2016-17 and AY 2017-18. 8.3 The learned AO / DRP erred in not appreciating that the balance difference of Rs.62,71,563 is on account of difference in opening written

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, AY 2016-17 and AY 2017-18. 8.3 The learned AO / DRP erred in not appreciating that the balance difference of Rs.62,71,563 is on account of difference in opening written

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. In case a decision is taken by the department to accept the decision of Hon’ble ITAT before the final order is passed , the order of the ITAT may be followed to avoid further litigation as the matter become final .” 10 15 . Further , it is observed that for assessment year 2011-12 (ITA No. 1478/Del/2017) and assessment year

KEVIN INTERNATIONAL,HARIDWAR vs. DCIT, CIRCLE HARIDWAR, HARIDWAR

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Us(Through Video Conferencing) M/S. Kevin International, Vs. Dy. Cit, C/O. Balesh Bhargava-Adv, Circle, Haridwar 56, Niranajani Akhara, Mayapur, Haridwar (Appellant) (Respondent) Pan: Aajfk4514C

56, Niranajani Akhara, Mayapur, Haridwar (Appellant) (Respondent) PAN: AAJFK4514C Assessee by : Shri. K. K. Juneja, Adv Revenue by: Smt Poonam Sharma, Add. CIT Date of Hearing 11/12/2023 Date of pronouncement 22/12/2023 O R D E R PER M. BALAGANESH, A. M.: 1. The appeal in ITA No. 5363/Del/2017 for AY 2012-13, arises out of the order of the Commissioner