GULF PIPING COMPANY WLL,ABU DHABI vs. DY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

Permanent Establishment in India (PE) of the non- resident in India, the same cannot be taxed. We have Bangalore in the case of ABB FZ-LLC which was a case rendered in the context of DTAA between India and UAE. The decision of the CIT(A) is in line with the decision referred to above and is a correct interpretation

BG INTERNATIONAL 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 and stay application filed by the assessee is dismissed

Bench: Shri R.K. Panda & Ms Suchitra Kambleasstt. Year 2017-18

established by determining the overall total cost of the skill centre (full employee related costs as well as costs allocated to that skill centre) and determining the hourly rate with reference to the numbers of chargeable hours Other Reimbursements:- BGEPIL has reimbursed several expenses to BGIL on a cost- to-cost basis. These expenses pertain to cost of stock option

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

In the result, appeal of the assessee in ITA No

Permanent Establishment (PE) and income computed at profit rate of 25% thereof. While doing so, the ld AO rejected the books of account and rejected book results shown by the assessee. In AY 2008-09, the Tribunal remanded the matter to the file of the ld AO with regard to determination of profit for outsource supply vide its order

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

In the result, appeal of the assessee in ITA No

Permanent Establishment (PE) and income computed at profit rate of 25% thereof. While doing so, the ld AO rejected the books of account and rejected book results shown by the assessee. In AY 2008-09, the Tribunal remanded the matter to the file of the ld AO with regard to determination of profit for outsource supply vide its order

SH. DEVENDRA DUTT PANT,HARIDWAR vs. DCIT , UTTARKAHAND

Appeal is partly allowed in above terms

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

permanent or temporary nature? 7) Whether the land, though entered in revenue records, had never been actually used for 8 Devendra Dutt Pant agriculture, that is, it had never been ploughed or tilled? Whether the owner meant or intended to use it for agricultural purposes? 8) Whether the land was situate in a developed area? Whether its physical characteristics, surrounding

PRAKASHI UNIYAL,DEHRADUN vs. ITO, KOTDWAR

In the result, appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishia Y 2009-10 Appellant Respondent Ms Praksahi Uniyal The Income Tax Officer F-27 Thdc Colony Vs. Kotdwar Ajabpur Dehradun Pan : Ccxpp8494E ( Appellant ) ( Respondent )

disallowance of exemption under section 54 of the income tax act is devoid of any merit. He submitted that assessee has sold the property for ₹ 10 lakhs on 3/1/2009. The land was purchased by the assessee for ₹ 8 19400 on 7/10/2008 and c== house was constructed in FY 2009-10. He showed the withdrawal made by the assessee from