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

vii) Taxability of contract receipt of Rs.1,38,08,610/- on accrual basis (viii) Disallowance of interest under section 14A. 3.1 Vide 5 grounds; the Revenue has raised following issues (i) Disallowance of employees’ contribution in ECGI under section 36(1)(va) r.w.s.2(24)(x) of the Act. (ii) Disallowance of interest of Rs.50,50,442/- on Government loans/ advances

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

vii) Taxability of contract receipt of Rs.1,38,08,610/- on accrual basis (viii) Disallowance of interest under section 14A. 3.1 Vide 5 grounds; the Revenue has raised following issues (i) Disallowance of employees’ contribution in ECGI under section 36(1)(va) r.w.s.2(24)(x) of the Act. (ii) Disallowance of interest of Rs.50,50,442/- on Government loans/ advances

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

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

Appeal is partly allowed in above terms

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

vii) Confirmation from Trust/ Gaushala to whom agricultural produce (grass, bajra) etc was provided by assessee (kindly see page 238 of PB). viii) Since the produce from land was used for self- consumption, as such, there was no occasion to have reported the said fact to Land/ Revenue Authorities. ix) Request made by assessee to AO for field visit