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

64,880 to the total income of the Appellant by erroneously applying CUP Method for determination of arm's length interest rate on the ECB taken from its AE. 7.2 Without prejudice to the above, the learned TPO / AO / DRP erred in not appreciating the fact that a substantial amount of loan was already repaid during previous assessment year

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

64,880 to the total income of the Appellant by erroneously applying CUP Method for determination of arm's length interest rate on the ECB taken from its AE. 7.2 Without prejudice to the above, the learned TPO / AO / DRP erred in not appreciating the fact that a substantial amount of loan was already repaid during previous assessment year

K L D A V COLLEGE,ROORKEE, HARIDWAR vs. ITO WARD 1(3)(4), ROORKEE, HARIDWAR

In the result, appeal of the assessee is allowed

Bench: SHRI YOGESH KUMAR U.S. (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

section 12A(1)(b) of the Income Tax Act 1961 and treating the gross receipts as Income without allowing revenue expenditures and depreciation on capital expenditures. 7. Without prejudice to the above the ADDL/JCIT has erred in law and facts in sustaining the addition for Rs. 1,82,59,837/- and Tax liability including interest and additional Income

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

In the result, appeal of the assessee in ITA No

64,04,45,015 declared by the assessee on the basis of percentage of Samsung Heavy Industries Co. Ltd. vs. DCIT (Int. tax.) completion method which has been followed by it regularly in earlier years. According to the assessee this variation has been made without any justification and without assigning any reasons. It has been submitted that

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

In the result, appeal of the assessee in ITA No

64,04,45,015 declared by the assessee on the basis of percentage of Samsung Heavy Industries Co. Ltd. vs. DCIT (Int. tax.) completion method which has been followed by it regularly in earlier years. According to the assessee this variation has been made without any justification and without assigning any reasons. It has been submitted that