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5 results for “disallowance”+ Section 135clear

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Key Topics

Section 143(1)11Section 36(1)(va)6Section 143(3)3Disallowance3Section 234C2Section 2502Permanent Establishment2Survey u/s 133A2Depreciation2

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

In the result, appeal of the assessee in ITA No

ITA 1315/DEL/2017[2008-09]Status: DisposedITAT Dehradun22 Dec 2023AY 2008-09
Section 143(3)Section 234C

135/-). While doing so, the learned AO held as under: Samsung Heavy Industries Co. Ltd. vs. DCIT (Int. tax.) 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

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

In the result, appeal of the assessee in ITA No

ITA 873/DEL/2017[2012-13]Status: DisposedITAT Dehradun22 Dec 2023AY 2012-13
Section 143(3)
Addition to Income2
Section 234C

135/-). While doing so, the learned AO held as under: Samsung Heavy Industries Co. Ltd. vs. DCIT (Int. tax.) 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

DCIT, CIRCLE-1(1)(1), SUBHASH ROAD vs. UJVN LIMITED, GMS ROAD

In the result appeal of the assessee is partly allowed for statistical purposes

ITA 126/DDN/2025[2017-18]Status: DisposedITAT Dehradun27 Nov 2025AY 2017-18
Section 143(1)Section 250Section 36(1)(va)

135 taxmann 201 (Delhi Tribunal) allowing the depreciation on the asset\nreceived by the assessee on the demerger is not attained finality.\n4. It is further seen that following the said order in assessee's own case for\n Assessment Year 2018-29 as well as in AY 2021-22 and in AY 2022-23 in ITA\nNo.153/DDN/2024, ITA No.154/DDN/2024

SHRI SHIV MANDIR PRABANDH,DEHRADUN vs. ITO, WARS 1(2)(3) , DEHRADUN, DEHRADUN

In the result, Appeal of the Assessee is allowed

ITA 252/DDN/2025[2018-19]Status: DisposedITAT Dehradun18 Feb 2026AY 2018-19

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthishiv Mandir Prabandh Samiti Vs Ito 135, Dharampur, Uttarakhand Ward-1(2)(3) Pan: Aayas3503P Dehradun, Uttarakhand Appellant Respondent Assessee By Sh. Rajiv Sahni, Ca Revenue By Sh. A. S. Rana, Sr. Dr Date Of Hearing 10/02/2026 Date Of Pronouncement 18/02/2026

Section 12ASection 143Section 143(1)Section 143(3)

135, Dharampur, Uttarakhand Ward-1(2)(3) PAN: AAYAS3503P Dehradun, Uttarakhand Appellant Respondent Assessee by Sh. Rajiv Sahni, CA Revenue by Sh. A. S. Rana, Sr. DR Date of Hearing 10/02/2026 Date of Pronouncement 18/02/2026 ORDER PER YOGESH KUMAR, U.S. JM: The present appeal is filed by the Assessee against the order of Ld. Commissioner of Income Tax (Appeals/ National

M/S UJVN LIMITED ,UTTARAKHAND vs. DEPUTY COMMISSIONER OF INCOME TAX, UTTARAKHAND

In the result appeal of the assessee is partly allowed for statistical purposes

ITA 127/DDN/2025[2024-25]Status: DisposedITAT Dehradun27 Nov 2025AY 2024-25
Section 143(1)Section 250Section 36(1)(va)

135 taxmann 201 (Delhi Tribunal) allowing the depreciation on the asset\nreceived by the assessee on the demerger is not attained finality.\n4.\nIt is further seen that following the said order in assessee's own case for\n Assessment Year 2018-29 as well as in AY 2021-22 and in AY 2022-23 in ITA\nNo.153/DDN/2024, ITA No.154/DDN/2024