RAJESH AGGARWAL ,DEHRADUN vs. THE DEPUTY COMMISSIONER OF INCOME TAX OFFICER, CENTRAL CIRCLE, DEHRADUN

In the result, all the appeals of the assessee are allowed

45,850 2012-13 2,52,895 2013-14 2,58,770 2014-15 2,96,370 2015-16 3,48,770 23. In view of above observations, the grounds raised by the assessee for assessment years 2011-12 to 2015-16 together with the additional grounds thereon are disposed of in the above mentioned manner

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

disallowance of expenses on various grounds. The assessee pleaded before the ld AO that its income from the execution of the two contracts should be determined in accordance with the provisions of section 44BB(1) of the Act. The assessee also gave detailed note on contract income earned by it with ONGC, Petrogas E&P LLC. As under:- 3.0 Detailed

ASSISTANT COMMISSIONER OF INCOME TAX, DEHRADUN vs. WESTERN GECO INTERNATIONAL LIMITED, HARYANA

The Appeal of the Revenue is dismissed

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 141/Del/2024 (A.Y 2021-22)

45,762/- in respect of its contracts with Oil Natural Gas ACIT vs. Western Geco International Ltd. Corporation Limited for hiring of services for 4C-3D OBN data processing & interpretation of data D1 to be in the nature of fees for technical services under section 9(1)(vii) of the Act. 5. Aggrieved by the assessment order dated 11/03/2024

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

2) In particular, and without prejudice to the generality of the foregoing power, such rules may provide for all or any of the following matters :— ………………… (ha) the procedure for granting of relief or deduction, as the case may be, of any income-tax paid in any country or specified territory outside India, under section 90 or section 90A or section

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

Appeal is partly allowed in above terms

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

section 54B of the Act be allowed to assessee - appellant. ISSUE NO. 2 IS WITH REGARDS TO DENIAL OF INDEXED COST OF ACQUISITION OF A SUM OF RS. 5,33,063/- 8. In this regards, it is most humbly submitted that the assessee had claimed indexed cost of acquisition of a sum of Rs. 31,26,815/-, out of which

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

In the result, appeal of the assessee in ITA No

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 by the ld AO after holding „inside India revenue

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

In the result, appeal of the assessee in ITA No

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 by the ld AO after holding „inside India revenue

ANUJ KUMAR,DEHRADUN vs. ACIT DCIT CENTRAL CIRCLE, DEHRADUN

In the result, the Appeal of the Assessee is allowed

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Anuj Kumar Vs. Acit Dcit Central Circle, Haripur, Kalsi, Dehradun, Investigation Wing, Cross Road, Uttarakhand Dehradun, Uttarakhand Pan: Aetpk0635A Appellant Respondent Assessee By Sh. Harshit Gupta, Ca Revenue By Sh. S. K. Chatterjee, Cit(Dr) Date Of Hearing 10/07/2025 Date Of Pronouncement 06/08/2025 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Order Of Ld.

2 ANUJ KUMAR Vs. ACIT 3) The learned CIT(Appeals) disregarded the appellant's submissions regarding the non-applicability of the disallowance of Cash expenditure under Section 40A(3), given that the assessee was offering income under Section 44AD of the IT Act. Consequently, the provisions of Section 40A(3) were not pertinent. Despite this, the learned CIT(Appeals) displayed

GULF PIPING COMPANY WLL,UNITED ARAB EMIRATES vs. DY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), DEHRADUN

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

2) of the Act. It is argued that the provisions which are more beneficial - i.e. Treaty provisions or Income-tax Act, i.e. either of the two should be applied;  Further, the appellant has also drawn attention to the fact that the decision of Hon'ble ITAT Chennai in the case of DCIT vs. TVS Electronics (Supra) has been overruled

GULF PIPING COMPANY WLL,UNITED ARAB EMIRATES vs. DY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), DEHRADUN

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

2) of the Act. It is argued that the provisions which are more beneficial - i.e. Treaty provisions or Income-tax Act, i.e. either of the two should be applied;  Further, the appellant has also drawn attention to the fact that the decision of Hon'ble ITAT Chennai in the case of DCIT vs. TVS Electronics (Supra) has been overruled

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

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

2) of the Act. It is argued that the provisions which are more beneficial - i.e. Treaty provisions or Income-tax Act, i.e. either of the two should be applied;  Further, the appellant has also drawn attention to the fact that the decision of Hon'ble ITAT Chennai in the case of DCIT vs. TVS Electronics (Supra) has been overruled

MRS. DHOOMI DEVI,CHAMOLI vs. ITO, W-1(4)4, SRINAGAR, CHAMOLI

In the result, appeal of the assessee is partly allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2022-23] Mrs. Dhoomi Devi Vs Ito C/O-Hotel Udai Palace Near . Ward-1(4)4 Narsingh Temple Srignagar, Chamoli Joshimath Chamoli, Uttarakhand-246174 Uttarakhand-246443 Pan-Adkpd6984B Appellant Respondent Assessee By Shri Tarandeep Singh, Adv. Revenue By Shri A.S. Rana, Sr. Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 13.02.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 08.08.2024 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Nfac/2021-22/10329482 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 05.03.2024 Passed U/S 143(3) R.W.S. 144B Of The Act Pertaining To Assessment Year 2022-23. 2. Brief Facts Of The Case Are That Assessee Is An Individual & The Case Was Selected For Scrutiny Under Cass For Reason I.E. “Large Investment In Immovable Property As Compared To The Total Income”. The Ao Than Passed The Assessment Order U/S 143(3) R.W.S. 144B On 05.03.2024 At A Total Income Of Inr 2,70,31,224/- As Against The Total Income Declared At Inr 29,45,000/- In The Return Of Income Filed By The Assessee.

45,000/- in the return of income filed by the assessee. 3. During the year under appeal, assessee had sold a property and purchased another property and claimed deduction of INR 1,90,86,224/- u/s 54F of the Act which was disallowed by holding that the assessee is owner of more than one residential property. Besides this, an addition

SAWINDER JEET SINGH KALER,NANITAL vs. ITO, WARD-2(3)(1), , NANITAL

Appeal is partly allowed

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh(Through Video Conferencing) Assessment Year: 2017-18 Sh. Sawinder Jeet Singh Vs. Income Tax Officer, Kaler, Ward-2(3)(1), Gol Ghar, Mallital, Nainital, Nainital Uttarakhand Pan :Alypk9431G (Appellant) (Respondent) Assessee By None Department By Sh. Amar Pal Singh, Sr. Dr

section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). 2. Case called twice. None appears at the assessee’s behest. He is accordingly proceeded ex-parte. 3. The assessee’s twin substantive grounds herein seek to reverse both the learned lower authorities’ action, inter alia, disallowing his agricultural income of Rs.9

NEERAJ SINGHAL,DEHRADUN vs. DCIT ACIT CEN CIR , DDN , DEHRADUN

In the result, the appeal of the assessee is allowed

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh(Through Video Conferencing) Neeraj Singhal, Vs. Dcit/Acit, Haripur, Kalsi, Dehradun, Central Circle, Uttarakhand Dehradun (Appellant) (Respondent) Pan: Apzps7059D Assessee By : Shri Harshit Gupta, Ca Revenue By: Shri S. K. Chaterjee, Cit Dr Date Of Hearing 19/03/2025 Date Of Pronouncement 09/04/2025

2) The learned CIT (Appeals) has erred in law and on fact by confirming the addition of Rs. 5,00,000 under Section 69C of the Income Tax Act, 1961, Imposed by the Assessing Officer, despite the assessment being carried out under Section 40A(3). The addition was made solely because the appellant did not provide an explanation

M/S THDC INDIA LIMITED, RISHIKESH,RISHIKESH vs. PCIT, DEHRADUN, DEHRADUN

In the result, appeal of the assessee is partly allowed

2\n3.\n4.\n2.1. The incomes are directly and inextricably linked with the power\ngenerating business and cannot be disentitled from the benefit of\n80-1A deduction\n2.2. The Hon'ble CIT(A) has completely ignored the detailed\nsubmissions made by the Appellant in this regard and blindly\nfollowed the orders of its predecessors.\nThat on the facts and circumstances