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

In the result, appeal of the assessee in ITA No

89,04,947/- claimed on account of hook up and commissioning, the same was paid to 'Offshore Hook up and Construction Services India Pvt. Ltd.' for which the TDS was deducted, hence, the AO Samsung Heavy Industries Co. Ltd. vs. DCIT (Int. tax.) allowed the said amount to the assessee. He found that TDS on pre- engineering and survey

HARSIL GANGOTRI FRUITS PROCESSING AND MARKETING PRIVATE LIMITED,RISHIKESH vs. CIT(A)-3, NOIDA, CIT(A) NOIDA AND ITO RISHIKESH

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal(Through Video Conferencing) Assessment Year: 2017-18 Harsil Gangotri Fruits Vs. Cit(A)-3, Processing & Marketing Pvt. Noida Ltd., Plot No. 89, Nirmal Bagh Aam Bagh, Visthapit Pashulok, Rishikesh, Dehradun, Uttarakhand Pan :Aacch9436Q (Appellant) (Respondent) With Assessment Year: 2017-18 Taknor Jhala Fruits Collection Vs. Cit(A)-3 & Processing Pvt. Ltd., Noida Plot No. 89, Nirmal Bagh Aam Bagh, Visthapit Pashulok, Rishikesh, Dehradun, Uttarakhand Pan :Aaect2878A (Appellant) (Respondent)

89, Nirmal Bagh Aam Bagh, Visthapit Pashulok, Rishikesh, Dehradun, Uttarakhand PAN :AAECT2878A (Appellant) (Respondent) Assessee by None Department by Sh. Amar Pal Singh, Sr. DR Date of hearing 12.01.2026 Date of pronouncement 12.01.2026 ITA Nos.31 & 32/DDN/2024 ORDER PER SATBEER SINGH GODARA, JM: These twin assessee’s ‘M/s. Harsil Gangotri Fruits Processing and Marketing Pvt. Ltd.’ and ‘M/s. Taknor Jhala Fruits

TAKNOR JHALA FRUITS COLLECTION AND PROCESSING PRIVATE LIMITED,RISHIKESH, UTTRAKHAND vs. CIT(A)-3, NOIDA, CIT(A)-THREE, NOIDA AND ITO RISHIKESH

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal(Through Video Conferencing) Assessment Year: 2017-18 Harsil Gangotri Fruits Vs. Cit(A)-3, Processing & Marketing Pvt. Noida Ltd., Plot No. 89, Nirmal Bagh Aam Bagh, Visthapit Pashulok, Rishikesh, Dehradun, Uttarakhand Pan :Aacch9436Q (Appellant) (Respondent) With Assessment Year: 2017-18 Taknor Jhala Fruits Collection Vs. Cit(A)-3 & Processing Pvt. Ltd., Noida Plot No. 89, Nirmal Bagh Aam Bagh, Visthapit Pashulok, Rishikesh, Dehradun, Uttarakhand Pan :Aaect2878A (Appellant) (Respondent)

89, Nirmal Bagh Aam Bagh, Visthapit Pashulok, Rishikesh, Dehradun, Uttarakhand PAN :AAECT2878A (Appellant) (Respondent) Assessee by None Department by Sh. Amar Pal Singh, Sr. DR Date of hearing 12.01.2026 Date of pronouncement 12.01.2026 ITA Nos.31 & 32/DDN/2024 ORDER PER SATBEER SINGH GODARA, JM: These twin assessee’s ‘M/s. Harsil Gangotri Fruits Processing and Marketing Pvt. Ltd.’ and ‘M/s. Taknor Jhala Fruits

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

KARAM SAFETY PRIVATE LIMITED,SITARGANJ 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

SBL PVT. LTD.,UTTRAKHAND vs. DCIT, DEHRADUN

In the result, appeal of the assessee is dismissed

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A No.540/Del/2017 िनधा"रणवष"/Assessment Year:2012-13 बनाम Sbl Pvt. Ltd. Dcit Iie, Sidcul, Plot No.3, Vs. Office Of Commissioner Sector-12, Ranipur, Haridwar, Of Income Tax, Uttarakhand. Dehradun. Pan No Aaics9462M अपीलाथ" Appellant ""यथ"/Respondent

disallowance u/s 80IC on sale of scrap of Rs.5,40,548/-. 4. Brief facts are that the assessee company is engaged in the business of manufacturing and trading of homeopathy medicines and cosmetics filed return of income on 20.09.2012 declaring income of Rs.20,89,28,360/-. The assessment was completed u/s 143(3) on I.T.A. No. 540/Del/2017 24.03.2015 determined

M/S. JAIPRAKASH POWER VENTURES LTD.,,H.P. vs. DCIT, DEHRADUN

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 Vs. Dcit, M/S, Jaiprakash Power Ventures Ltd., Circle-2, 113, Rajpur Road, Dehradun Dehradun Pan: Aaacj5463 (Appellant) (Respondent) With Assessment Year: 2008-09 Vs. M/S, Dcit, Jaiprakash Power Circle-2, Ventures Ltd., Dehradun Juit, Complex, Waknaghat, Post Office- Dumehar Bani, Kandaghat, Distt. Solan, Himachal Pradesh Pan: Aaacj5463 (Appellant) (Respondent) Assessee By Sh. Anil K. Chopra, Ca Sh. Sanjiv Choudhary, Ca Sh. V.K. Garg, Adv. Department By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 20.03.2025 Date Of Pronouncement 23.05.2025

89 (SC). CIT v. Pawan Kumar Jain 298 ITR 443 (Del.), CIT v. Shahi Export House 195 Taxman 163 (Del.) and CIT v. Nectar Life Science Ltd. 2011-TIOL-681- HC-DEL-IT. 7. That without prejudice to other grounds, otherwise too, the Ld. CIT (Appeals) has erred in not holding that the said interest income

DCIT, DEHRADUN vs. M/S JAI PRAKASH POWER VENTURE LTD., H.P.

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 Vs. Dcit, M/S, Jaiprakash Power Ventures Ltd., Circle-2, 113, Rajpur Road, Dehradun Dehradun Pan: Aaacj5463 (Appellant) (Respondent) With Assessment Year: 2008-09 Vs. M/S, Dcit, Jaiprakash Power Circle-2, Ventures Ltd., Dehradun Juit, Complex, Waknaghat, Post Office- Dumehar Bani, Kandaghat, Distt. Solan, Himachal Pradesh Pan: Aaacj5463 (Appellant) (Respondent) Assessee By Sh. Anil K. Chopra, Ca Sh. Sanjiv Choudhary, Ca Sh. V.K. Garg, Adv. Department By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 20.03.2025 Date Of Pronouncement 23.05.2025

89 (SC). CIT v. Pawan Kumar Jain 298 ITR 443 (Del.), CIT v. Shahi Export House 195 Taxman 163 (Del.) and CIT v. Nectar Life Science Ltd. 2011-TIOL-681- HC-DEL-IT. 7. That without prejudice to other grounds, otherwise too, the Ld. CIT (Appeals) has erred in not holding that the said interest income

M/S. JAIPRAKASH POWER VENTURES LTD.,DEHRADUN vs. DCIT, DEHRADUN

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 Vs. Dcit, M/S, Jaiprakash Power Ventures Ltd., Circle-2, 113, Rajpur Road, Dehradun Dehradun Pan: Aaacj5463 (Appellant) (Respondent) With Assessment Year: 2008-09 Vs. M/S, Dcit, Jaiprakash Power Circle-2, Ventures Ltd., Dehradun Juit, Complex, Waknaghat, Post Office- Dumehar Bani, Kandaghat, Distt. Solan, Himachal Pradesh Pan: Aaacj5463 (Appellant) (Respondent) Assessee By Sh. Anil K. Chopra, Ca Sh. Sanjiv Choudhary, Ca Sh. V.K. Garg, Adv. Department By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 20.03.2025 Date Of Pronouncement 23.05.2025

89 (SC). CIT v. Pawan Kumar Jain 298 ITR 443 (Del.), CIT v. Shahi Export House 195 Taxman 163 (Del.) and CIT v. Nectar Life Science Ltd. 2011-TIOL-681- HC-DEL-IT. 7. That without prejudice to other grounds, otherwise too, the Ld. CIT (Appeals) has erred in not holding that the said interest income

M/S. JAIPRAKASH POWER VENTURES LTD.,DEHRADUN vs. DCIT, DEHRADUN

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 Vs. Dcit, M/S, Jaiprakash Power Ventures Ltd., Circle-2, 113, Rajpur Road, Dehradun Dehradun Pan: Aaacj5463 (Appellant) (Respondent) With Assessment Year: 2008-09 Vs. M/S, Dcit, Jaiprakash Power Circle-2, Ventures Ltd., Dehradun Juit, Complex, Waknaghat, Post Office- Dumehar Bani, Kandaghat, Distt. Solan, Himachal Pradesh Pan: Aaacj5463 (Appellant) (Respondent) Assessee By Sh. Anil K. Chopra, Ca Sh. Sanjiv Choudhary, Ca Sh. V.K. Garg, Adv. Department By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 20.03.2025 Date Of Pronouncement 23.05.2025

89 (SC). CIT v. Pawan Kumar Jain 298 ITR 443 (Del.), CIT v. Shahi Export House 195 Taxman 163 (Del.) and CIT v. Nectar Life Science Ltd. 2011-TIOL-681- HC-DEL-IT. 7. That without prejudice to other grounds, otherwise too, the Ld. CIT (Appeals) has erred in not holding that the said interest income

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

SAURAV MALIK,DEHRADUN vs. INCOME TAX OFFICER, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2017-18] Saurav Malik Vs Ito 100/2, Bell Road Clement Town 15A, Subhash Road, Near Hilton School, Dehradun Uttarakhand Uttarakhand-248002 Pan-Bdypm6527J Appellant Respondent Assessee By Shri Rajiv Sahini, Ca Revenue By Shri A.S. Rana, Sr. Dr Date Of Hearing 09.10.2025 Date Of Pronouncement 24.12.2025

89,685/- by holding the cash credited in his bank accounts as his undisclosed income u/s 69A of the Act. 3. Against the said order, assessee filed an appeal before Ld. CIT(A) which stood dismissed vide order dated 31.01.2025. 4. Aggrieved by the order of Ld. CIT(A), the assessee is in appeal before the Tribunal by taking following

B R MORDEM SCHOOL SAMITI,PAURI vs. I T O, EXEMPTION WARD DEHRADUN, DEHRADUN

In the result, the appeal of the assessee is allowed

section 10(23C)(iiiad) and the corpus\ndonation received with specific direction to develop infrastructure\nfacilities is a capital receipts. Therefore, Ld.AR requested that the\nassessee's society be grant the exemption u/s 10(23C)(iiiad) of the\nAct since its annual receipts are less than Rs.1.00 crores which is\nthe threshold limit for claiming exemption u/s 10(23C)(iiiad