KARAM SAFETY PRIVATE LIMITED,UDHAM SINGH NAGAR vs. THE INCOME TAX OFFICER, WARD-2(3)(5), UDHAM SINGH NAGAR

In the result, both the appeals of the assessee are allowed and that of the Stay Applications are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

disallowing deduction u/s 80IC/Chapter VI-A of the Act. 4. On the facts and circumstances of the case and in law, the Ld. AO/DRP have failed to appreciate that to invoke the provisions of Section 92BA, existence of any 'arrangement' to ‘more than ordinary profits’ between the Appellant and its Associate Enterprise (“AE”) need to be established under the provisions

BR ASSOCIATES ,UTTARAKAHAND vs. ACIT , RISHIKESH

In the result, the appeal of the assessee is allowed and the assessment order is quashed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2016-17] M/S. B R Associates Vs Acit Jolly Grant, Circle-1(4)(1) Bhaniyawala, Dehradun, Rishikesh, Uttarakhand-248140 Uttarakhand-249201 Pan-Aaqfb6241E Appellant Respondent Assessee By Shri Kanwal K.Juneja, Ca Revenue By Shri A.S.Rana, Sr.Dr Date Of Hearing 10.12.2025 Date Of Pronouncement 18.02.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 08.07.2025 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Cit(A), Dehradun/10296/2018-19 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 28.12.2018 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2016-17. 2. Brief Facts Of The Case Are That The Assessee Is An Individual & Filed Its Return Of Income On 08.10.2016 Declaring Total Income At Inr 46,02,250/-. The Case Was Selected For Scrutiny Under Cass & The Notice Was Issued By Ito, Ward-1(2), Dehradun Thereafter, The Case Was Transferred To Dcit, Circle-1(1)(1), Dehradun. Thereafter, Various Notices Were Issued & Replies Were Filed By The Assessee. After Considering The Submissions, Total Income Was Assessed At Inr 1,93,96,755/- By Making Addition Of Inr 55.00 Lakhs Towards Bogus Advances & Inr 14,13,600/- As Deemed Income & Further Disallowance Of Expenses Of Inr 78,80,905/- Was Made.

section 43CA is not applicable in the instance appeal, therefore, requested to please delete the addition of Rs.14, 13,600/- as made by the authorities below. 7. That in facts and circumstances of the case, that the appellant give the discount about 2% as business promotion on the value stamp duty authorities on Rs.7,16,84,200/-and books

PURAN SINGH NEGI,HALDWANI vs. THE ASSIST COMMISSIONER OF INCOME TAX , NANITAL

In the result, the appeal of the assessee is allowed for statistical purpose

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.I.T.A. No. 33/Ddn/2020 (A.Y 2016-17)

disallowed. Accordingly, income of the assessee was assessed at Rs. 38,67,996/- against the returned income as per the revised return of income at Rs. 37,17,350/-. The Ld.CIT(A) by considering the relevant provision u/s 10(1) & 10(10C) of the Act, found that claim made by the assessee is genuine and based on bonafide ground even

M/S. UTTARAKHAND PURV SAINIK KALYAN NIGAM LTD.,DEHRADUN vs. ITO, DEHRADUN

In the result, the appeal of the assessee is dismissed

Bench: Shri Anubhav Sharma & Shri Brajesh Kumar Singh[Assessment Year: 2013-14] M/S Uttrakhand Purv Ito,Ward-2(5), Sainik Kalyan Nigam Ltd. Aayakar Bhawan,13-A, Subhash (Upnl) Vs Road, Dehradun Uttrakhand- Station Sub Area, Garhi 248003 Cantt, Dehradun-248003 Pan-Aaacu7129D Assessee Revenue Assessee By Shri Tarandeep Singh, Adv. Revenue By Shri Amar Pal Singh, Sr. Dr Date Of Hearing 31.01.2025 Date Of Pronouncement 19.03.2025

2. That, Ld. CIT(A) and Ld Assessing Officer erred in holding that the appellant was not established by the a central, state or provisional act, both the Ld. A.O. and the CIT(A) erred in justifying that: a. That Uttarakhand Purv Sainik Kalyan Nigam Limited was established by Government of Uttarakhand for welfare and economic upliftment of ex-serviceman

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

In the result, the appeal of the assessee is allowed

2) of section 44AA and gets his accounts audited and furnishes a report of such audit as required under section 44AB, and thereupon the Assessing Officer shall proceed to make an assessment of the total income or loss of the assessee under sub-section (3) of section 143 and determine the sum payable by, or refundable to, the assessee

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

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 the AO and DRP have grossly erred on facts and in law in making disallowance of Rs 20,22,921/- being payment to Global Marine Technologies. 12. That

ACIT, CIRCLE- 3, NAINITAL vs. KUMAON MANDAL VIKAS NIGAM LTD., NAINITAL

In the result, both appeals of the Revenue are partly allowed as above

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 2(24)(x) r.w.s. 36(1)(va) and 43B of the Act. The Ld. Senior Departmental Representative (hereinafter ‘Ld. DR’), placing reliance on the decision of the Hon’ble Supreme Court in the case of Checkmate Services P. Ltd. [(2022) 448 ITR 518 (SC)], requested for upholding of the disallowances, to which the Ld. Counsel seemed

ACIT, NAINITAL vs. M/S. KUMAON MANDAL VIKAS NIGAM LTD., NAINITAL

In the result, both appeals of the Revenue are partly allowed as above

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 2(24)(x) r.w.s. 36(1)(va) and 43B of the Act. The Ld. Senior Departmental Representative (hereinafter ‘Ld. DR’), placing reliance on the decision of the Hon’ble Supreme Court in the case of Checkmate Services P. Ltd. [(2022) 448 ITR 518 (SC)], requested for upholding of the disallowances, to which the Ld. Counsel seemed

MUSSOORIE DEHRADUN DEVELOPMENT AUTHORITY,MDDA, TRANSPORT NAGAR DEHRADUN vs. ASSISTANT COMMISSIONER OF INCOME TAX, NATIONAL FACELESS ASSESSMENT CENTRE

In the result, both appeals of the assessee are dismissed as above

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

disallowance of Rs.28,080/- under section 43B r.w.s. 36(1)(va) of the Act is concerned, the Ld. AR submitted that the amount of Rs.28,080/- had been paid after the due date specified in the said Provident Act. However, the same had been paid before filing of the ITR. The Ld. AR submitted that the issue involved in this

MUSSOORIE DEHRADUN DEVELOPMENT AUTHORITY,MDDA, TRANSPORT NAGAR DEHRADUN vs. ASSISTANT COMMISSIONER OF INCOME TAX, INCOME TAX DEPARTMENT DEHRADUN

In the result, both appeals of the assessee are dismissed as above

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

disallowance of Rs.28,080/- under section 43B r.w.s. 36(1)(va) of the Act is concerned, the Ld. AR submitted that the amount of Rs.28,080/- had been paid after the due date specified in the said Provident Act. However, the same had been paid before filing of the ITR. The Ld. AR submitted that the issue involved in this

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 1(1)(1), DEHRADUN, DEHRADUN vs. THDC INDIA LIMITED, TEHRI

In the result, the appeal of the Revenue is dismissed as above

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Disallowance of deduction claimed under 59,39,91,068/- section 80IA of the Act 2. Addition on account of late payment 280,34,10

INSTITUTE OF CLINICAL RESEARCH INDIA SOCIETY,DEHRADUN vs. CIT(A), DEHRADUN

Appeal is allowed

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh(Through Video Conferencing) Assessment Year: 2012-13 Institute Of Clinical Research Vs. Commissioner Of Income India Society, Tax (Appeals), 1St Floor, Building No.1, Dehradun Treenetra Vihar, Near Kargt Chowk, Dehradun Pan :Aabai3710P (Appellant) (Respondent) Assessee By None Department By Sh. Amar Pal Singh, Sr. Dr

sections 147 r.w.s. 144 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). 2. Case called twice. None appears at the assessee’s behest. It is accordingly proceeded ex-parte. 3. Learned departmental representative vehemently argues during the course of hearing that both the learned lower authorities have rightly disallowed the assessee’s expenditure claim

DCIT, RISHIKESH vs. M/S UTTRANCHAL IRON & ISPAT LTD.,, KOTDWAR

In the result, this appeal of the assessee (ITA No

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

section 145 of the Income Tax Act, 1961 as discrepancies found in the books and the book results shown by the assessee was not amenable to verification. 2. The Ld. CIT (A) has erred in law and on facts in deleting addition of Rs. 11,54,74,533/ out of Rs. 13,76,29,909/ made on account of bogus

UTTRANCHAL IRON & ISPAT LTD.,KOTDWAR vs. DCIT, CIRCLE- 1(4)(1), RISHIKESH

In the result, this appeal of the assessee (ITA No

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

section 145 of the Income Tax Act, 1961 as discrepancies found in the books and the book results shown by the assessee was not amenable to verification. 2. The Ld. CIT (A) has erred in law and on facts in deleting addition of Rs. 11,54,74,533/ out of Rs. 13,76,29,909/ made on account of bogus

INCOME TAX OFFICER, WARD-1(1)(3), DEHRADUN, AAYKAR BHAWAN, SUBHASH ROAD, DEHRADUN vs. UTTARAKHAND PURV SAINIK KALYAN NIGAM LIMITED, STATION SUB AREA

In the result, appeal of the assessee is allowed

Bench: Sh. Yogesh Kumar U.S. & Sh. Manish Agarwal

2. Brief facts of the case: The appellant is a company established under section 617 of the Companies Act, 1956, with its primary mission to extend support to ex- servicemen and their dependents through the provision of employment, financial assistance, loans, and grants, as well as offering training for entrepreneurship. The appellant primarily earns its income through manpower deployment contracts

DCIT, CIRCLE- I, INTERNATIONAL TAXATION, DEHRADUN vs. EXPRESS DRILLING SYSTEMS LLC, DEHRADUN

In the result, cross objection filed by the assessee is partly

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshआ.अ.सं/.I.T.A No.6114/Del/2017 िनधा"रणवष"/Assessment Year: 2009-10 बनाम Dcit, Express Drilling Circle-1, Vs. Systems Llc, International Taxation, C/O Nangia & Co., 1St Floor, Ida, 46, Dehradun, Uttarakhand. E.C. Road, Dehradun, Uttarakhand. Pan No.Aabce6891R अपीलाथ" Appellant ""यथ"/Respondent & Cross Objection No. 13/Del/2018 (In I.T.A No.6114/Del/2017) िनधा"रणवष"/Assessment Year: 2009-10 बनाम Express Drilling Systems Llc, Dcit, Vs. C/O Nangia & Co., Circle-1, 1St Floor, Ida, 46, International Taxation, E.C. Road, Dehradun, Dehradun, Uttarakhand. Uttarakhand. Pan No. Aabce6891R अपीलाथ" Appellant ""यथ"/Respondent

disallowing standby I.T.A.No.6114/Del/2017 & CO No. 13/Del/2018 charges totaling to Rs.54,600,000/- on the ground of business exigency and business prudence not proved by the appellant.” 2. In the cross objection filed by the assessee, the assessee challenged the validity of the final assessment order passed by the Assessing Officer u/s 143(3)/144C r.w.s. 254 of the Income

AJAY THAKUR ,DEHRADUN vs. ITO, WARD-1(1)(1)1, DEHRADUN, DEHRADUN

Appeal is partly allowed

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra(Through Video Conferencing) Assessment Year: 2017-18 Vs. Income Tax Officer, Sh. Ajay Thakur, S/O- Sh. Surendra Singh, 31-Purbiya Ward-1(1)(1)1, Lines, Hospital Road, Dehradun Vikas Nagar, Dehradun Pan: Afkpt5059D (Appellant) (Respondent) Assessee By Sh. Rajiv Sahni, Ca Department By Sh. A.S. Rana, Sr. Dr Date Of Hearing 10.01.2025 Date Of Pronouncement 27.01.2025 Order

2)(vii)(b) addition of Rs.19,46,500/- in very terms. 3 | P a g e 7. Learned counsel submits that the assessee’s second substantive issue canvassed in the instant appeal challenges both the lower authorities’ action making section 69 unexplained investment addition of Rs.12 lakhs which has been held liable to be assessed under section 115BBE

BHANIYAWALA KISAAN SEWA SAHKARI SAMITI LIMITED,DEHARADUN vs. THE INCOME TAX OFFICER, WARD-1(1)(2), DEHRADUN

In the result, appeal filed by the assessee is dismissed

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

disallowed deduction u/s 80P of the Income Tax Act 1961 on the ground that the assessee has not filed its income return and also not considered that the assessee is co- operative society. 4. That on the facts and in circumstances of the case the Ld. CIT(A) has erred not considering Income Tax Return submitted during the assessment proceeding

DCIT, DEHRADUN vs. M/S INSTITUTE OF CLINICAL RESEARCH (INDIA) SOCIETY,, DEHRADUN

In the result, the appeal filed by the assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

section 13 of the Income-tax Act, 1961 [the Act for short] is to be allowed in favour of the Revenue as the ld CIT(A) upheld the Assessing Officer’s stand that the assessee is not eligible for exemption u/s 11 of the Act. In view of the concession from the ld AR, the ground no 1 is allowed