KSHIPRA DHAWAN,SAHARANPUR vs. DCIT CEN CIR DDN, DEHRADUN

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

Bench: Shri Vimal Kumar & Shri Brajesh Kumar Singh

disallowance of Rs.17,51,912/- made u/s 40(a)(ia) of the Act was not sustainable u/s 143(1) of the Act dated 26.08.2019 as no order u/s 201(1) of the Act was passed by the AO in her case by treating her as an assessee in default for the non-deduction of TDS in regard to interest paid

KSHIPRA DHAWAN,SAHARANPUR vs. DCIT CEN CIR DDN, DEHRADUN

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

Bench: Shri Vimal Kumar & Shri Brajesh Kumar Singh

disallowance of Rs.17,51,912/- made u/s 40(a)(ia) of the Act was not sustainable u/s 143(1) of the Act dated 26.08.2019 as no order u/s 201(1) of the Act was passed by the AO in her case by treating her as an assessee in default for the non-deduction of TDS in regard to interest paid

BHUPENDRA BORA,GHAZIABAD vs. DCIT, DEHRADUN

In the result, the appeal is allowed

Bench: Shri M. Balaganesh & Shri Satbeer Singh Godara(Through Video Conferencing) Bhupendra Bora, Vs. Dcit, Flat No. S4, Plot No. 618A, Circle-1(1)(1), Sector-1, Vaishali, Dehradun Ghaziabad (Appellant) (Respondent) Pan: Ajkpb5486A Assessee By : None Revenue By: Shri A. S. Rana, Sr. Dr Date Of Hearing 17/03/2025 Date Of Pronouncement 02/04/2025

192 of the Act. In respect of services rendered outside India by the assessee i.e., from 1-1-2019 to 31-3- 2019, since the assessee was Resident and Ordinarily Resident, the said salary earned in Netherlands would also become taxable in India. The said salary was also subjected to tax in Netherlands and assessee had indeed duly paid

RAJIV KUMAR TIWARI,SAHARANPUR vs. DCIT-ACIT- CEN CIR DDN, DEHRADUN

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

Bench: Shri Vimal Kumar & Shri Brajesh Kumar Singhassessment Year: 2018-19 Rajiv Kumar Tiwari, Acit, Central Circle, A-7, Awas Vikas, Dehradun, Income Tax Office, 52/1, Delhi Road, Vs Rajpur Road, Dehradun Saharanpur, Uttarakhand-248001 Uttar Pradesh-247001 Pan-Adfpt9463L Appellant Respondent

disallowance of Rs.1,58,559/- made u/s 40(a)(ia) of the Act was not sustainable u/s 143(1) of the Act dated 17.06.2019 as no order u/s 201(1) of the Act was passed by the AO in his case by treating his as an assessee in default for the non-deduction of TDS in regard to interest paid

DY. COMMISSIONER OF INCOME TAX, DEHRADUN vs. HALLIBURTON OFF SHORE SERVICES INC , MAHARASHTRA

In the result, ground no.3 is allowed

Bench: Shri Yogesh Kumar Us & Shri Sanjay Awasthiआ.अ.सं/.I.T.A No.241/Ddn/2025 िनधा"रणवष"/Assessment Year:2021-22 बनाम Dy. Commissioner Of Income Halliburton Off Shore Services Inc.,Unit No.603, 6Th Floor, Tax, Vs. Aayakar Bhawan, 13-A, Subhash Satellite Gazebo, East Wing,Guru Road, Hargovindji Marg,Andheri Mumbai, Navi Dehradun, Uttarakhand. Mumbai,Maharashtra. Pan No.Aaach5154M अपीलाथ" Appellant ""यथ"/Respondent

section 40(a)(ia) of the Act cannot be made applicable to short deduction of tax at source a- z the disallowance made was deleted. Further the Hon'ble Delhi High Court in the case o* PCIT Vs. Future First Info Services Pvt. Ltd in ITA No. 195/2022 dated 14.07.2022 hadalso given the same proposition. The Id CIT(A) however

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

In the result, appeal of the assessee in ITA No

section 40(a)(ia) of the Act cannot be made applicable to short deduction of tax at source and the disallowance made was deleted. Further the Hon‟ble Delhi High Court in the case of PCIT Vs. Future First Info Services Pvt. Ltd in ITA No. 195/2022 dated 14.07.2022 had Samsung Heavy Industries Co. Ltd. vs. DCIT (Int. tax.) also

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

In the result, appeal of the assessee in ITA No

section 40(a)(ia) of the Act cannot be made applicable to short deduction of tax at source and the disallowance made was deleted. Further the Hon‟ble Delhi High Court in the case of PCIT Vs. Future First Info Services Pvt. Ltd in ITA No. 195/2022 dated 14.07.2022 had Samsung Heavy Industries Co. Ltd. vs. DCIT (Int. tax.) also

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.

disallowance may substantially be reduced. 11. That in facts and circumstances of the case, the addition as sustained by the CIT (A), NFAC may please be deleted.” Ground of appeal Nos.1 to 4 raised by the assessee are with 5. respect to the jurisdiction of the AO when the notice u/s 143(2) was issued by AO having no jurisdiction