HALLIBURTON OFFSHORE SERVICES INC.,NOIDA vs. DCIT (INTERNATIONAL TAXATION), CIRCLE-1, DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

9(1)(vii) since the “recipient” of FTS, the assessee in this case had not undertaken any construction, assembly, mining or like project. (vii) Whether the CIT (A) has erred in overlooking that the dominant purpose of the contract of the assessee was not prospecting, extraction or production of mineral oil so as to fall under purview of Section 44BB

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

9. That the AO and DRP have grossly erred on facts and in law in making disallowance of Rs 1,22,689/- on payment to Utkal Auto. 10. That the AO and DRP have grossly erred on facts and in law in making disallowance of Rs 5,41,080/- being payment to NOV Brandt Oilfield. 11. That

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

In the result, the appeal of the assessee is allowed

1) of the Act 9 ITA No.6608/Del./2016 or section 40(a)(i) of the Act would not survive. Similarly, the adjudication of additional ground for claim of income tax depreciation

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)

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 Tax at Rs. 1,61,64,410/- made by AO at CPC through automated process u/s 143(1) of the Income

SHIV RATAN EDUCATION SOCIETY,HARIDWAR vs. ITO EXEMPTION WARD, DEHRADUN

In the result, the appeal of the assessee is allowed

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

depreciation in the application of funds was inadvertently made by the assessee and when such error was pointed out, the assessee immediately corrected the same and filed the revised computation of income. It is further observed that all the facts are duly forming part of the information supplied in the return of income filed and there is no misrepresentation

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

In the result, appeal of the Revenue is partly allowed

1) read with sections 098 and 1158BE, of the Income-tax Act, 1961-Business Income Chargeable as (Excess stock) Assessment year 2018-19 Pursuant to survey conducted at assessee's premises under section 1334, assessee surrendered amount of Rs. 28.53 lakhs on account of excess stock over and above its normal business income Assessing Officer observed that surrendered income

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

In the result, appeal of the assessee in ITA No

1) That the assessee had a PE in India; 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

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

In the result, appeal of the assessee in ITA No

1) That the assessee had a PE in India; 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

ITO, HARIDWAR vs. M/S. PRITY JAIN PROP., HARIDWAR

In the result, appeal of the Revenue is dismissed

Bench: Shri Challa Nagendra Prasada N D Shrim. Balaganesh

depreciation into account. If such substantial expansion is completed, then, for the purpose of this section, the Assessment Year relevant to the P.Y. in which such substantial expansion is completed becomes the initial assessment year. Once it becomes the initial Assessment Year consequently under sub section (3) the assessee would be entitled to 100% deduction of profits and gains

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

depreciation has been allowed thereon. 5. The appellant craves permission to elucidate, add, amend, modify, delete any ground or grounds of appeal before the disposal in the interest of substantial justice.” 3. The assessee has raised the following additional grounds on 10.10.2023 which reproduced as under:- “1. On the facts and circumstances of the case