B G EXPLORATION & PRODUCTION INDIA LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME, DDIT/ ADIT (INTERNATIONAL TAXATION), CIRCLE-1, DEHRADUN, DEHRADUN

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

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

disallow Rs.3,43,90,634/- being the expenses holding that since the said expenses had been incurred for prospecting new business opportunities, therefore, the same were to be treated as pre-operative in nature and not allowable under section

B G EXPLORATION & PRODUCTION INDIA LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME, DDIT/ ADIT (INTERNATIONAL TAXATION), CIRCLE-1, DEHRADUN, DEHRADUN, UTTARAKHAND

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

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

disallow Rs.3,43,90,634/- being the expenses holding that since the said expenses had been incurred for prospecting new business opportunities, therefore, the same were to be treated as pre-operative in nature and not allowable under section

DCIT, RISHIKESH vs. M/S UTTRANCHAL IRON & ISPAT LTD.,, KOTDWAR

In the result, this appeal of the assessee (ITA No

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

90,630/- under section 80IC of the Income Tax Act, 1961 (hereinafter ‘the Act’). The case was picked up for scrutiny. Consequential assessment was completed at income of Rs.15,29,05,345/- making following additions and disallowances

UTTRANCHAL IRON & ISPAT LTD.,KOTDWAR vs. DCIT, CIRCLE- 1(4)(1), RISHIKESH

In the result, this appeal of the assessee (ITA No

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

90,630/- under section 80IC of the Income Tax Act, 1961 (hereinafter ‘the Act’). The case was picked up for scrutiny. Consequential assessment was completed at income of Rs.15,29,05,345/- making following additions and disallowances

ACIT, NAINITAL vs. M/S. THE NAINITAL BANK LTD., UTTRAKHAND

In the result, the appeal of the Revenue is dismissed

Bench: Hon’Ble Mr. Justice P.P. Bhatt & Shri G.S. Pannu, Hon’Bleassessment Year : 2013-14

disallowance u/s 14A r.w. Rule 8D(2)(ii) made by the A.O. was under the observation that the investment in tax free securities/funds, were made out of common pool of funds comprising more than 90% interest bearing funds. Besides, the assessee failed to establish nexus between investment in exempt securities and interest free funds. 3. The Ld.CIT(A) has erred

EXPRESS DRILLING SYSTEMS LLC,NOIDA vs. DCIT INTERNATIONAL TAXATION,, DEHRADUN

In the result ground number 2 of the appeal is dismissed

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishiexpress Drilling Systems Llc, Vs. Dict International Taxation, C/O. Nangia & Co, Circle-1, Dehradun A-109, Sector-136, Noida Pan: Aabce6891R (Appellant (Respondent)

Section 201 (1) of the act within 90 days from the date of this order, thereafter the learned CIT – A may examine himself or through the assessing officer the veracity of such information and if the same is found to be in order, the addition made u/s 40 (a)(ia) may be deleted to that extent. In view of this

RAKESH KUMAR JAIN,DEHRADUN vs. DCIT, DEHRADUN

Appeal of the assessee is allowed

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar

90,702/- as per Section 14A.” 3. The only issue involved in this case is disallowance u/s 14A.The assessee has shown

RAKESH KUMAR JAIN,DEHRADUN vs. DCIT, DEHRADUN

Appeal of the assessee is allowed

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar

90,702/- as per Section 14A.” 3. The only issue involved in this case is disallowance u/s 14A.The assessee has shown

U C JAIN & SONS,HARIDWAR vs. ITO, WARD- 3, HARIDWAR

In the result, the appeal is allowed for statistical purposes

Bench: Dr. B.R.R. Kumar & Sh. Yogesh Kumar U.S.Assessment Year: 2012-13 Uc Jain & Sons, Vs Ito, Ward-3, C/O M/S. Rishabh Velveleen Ltd., Haridwar. 9Th Km. Haridwar Delhi Road, Jwalapur, Haridwar. (Appellant) (Respondent) Pan No. Aaahu1616A

disallowed the deduction under section 80IB(10) of the Act for non production of the completion certificate. In our considered view, in the interest of justice, if an opportunity is given to the assesse to produce the completion certificate issued by the local authority in a stipulated time, which can be verified by the Assessing Officer and the benefit under

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

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

90(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

90(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

90(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

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

In the result, appeal of the assessee in ITA No

disallowance made by the Ld. AO amounting to Rs.2,81,90,744/- and Rs.4,20,03,868/- under section 40(a)(ia) of the Act for the payments

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

In the result, appeal of the assessee in ITA No

disallowance made by the Ld. AO amounting to Rs.2,81,90,744/- and Rs.4,20,03,868/- under section 40(a)(ia) of the Act for the payments

DDIT, DEHRADUN vs. M/S. DAELIM INDUSTRIAL COMPANY LIMITED, DEHRADUN

In the result, appeal of the Revenue is dismissed

Bench: Shri Challa Nagendra Prasada N D Shrim. Balaganesh

section 143(3) of the Income Tax Act, 1961 (the Act) by the Assessing Officer on 14.05.2013 determining the income of the assessee at Rs.21,32,33,040/-. While completing the assessment the Assessing Officer made disallowance of Rs.2,54,85,276/- out of administrative and other charges, professional and technical services and sub- contract charges of Rs.7

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.

disallowance of deduction claimed u/s 54F of Rs 1,90,86,224/-. 4. That on facts and in law the AO and CIT(A) have erred in not appreciating that conditions prescribed in clause (a) to proviso of section

ACIT, CIRCLE- 2, INTERNATIONAL TAXATION, DEHRADUN vs. SOLAR TURBINES INTERNATIONAL CO., BENGALURU

In the result, the appeal of the Revenue is dismissed

Bench: Dr. B.R.R. Kumar & Sh. Yogesh Kumar U.S.Assessment Year: 2014-15 Solar Turbines International Vs Dcit, Company (Singapore Branch Of Circle-2, Solar Turbines International International Taxation, Company, Usa), Dehradun. 14 Tractor Road, Singapore, C/O Delloitte Haskins & Sells Llp, Deloitte Centre Anchorage- Ii, Richmond Road, Bangalore. (Appellant) (Respondent) Pan No. Aajcs3585J Assessment Year: 2014-15

90(2) of the Act providing for application of beneficial rate of tax as per DTAA had not been applied and hence constituted mistake apparent on record. e) The learned CIT(A) erred in not upholding justice by adjudicating on merits of the rectification application. 2 Erroneous levy of surcharge and education cess a) The learned C1T(A) erred

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

90,42,19,404/- against interest income of Rs. 2,43,02,346/- for computing the profits and gains of business and eligible deduction u/s 801A of the appellant. As interest expenditure much exceeds the interest income, no interest amount was to be reduced in computing eligible deduction u/s 801A. 3. That the Ld. CIT(A) has erred

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

90,42,19,404/- against interest income of Rs. 2,43,02,346/- for computing the profits and gains of business and eligible deduction u/s 801A of the appellant. As interest expenditure much exceeds the interest income, no interest amount was to be reduced in computing eligible deduction u/s 801A. 3. That the Ld. CIT(A) has erred