MI OVERSEAS LTD.,NEW DELHI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

151 ITD 79 (Del) does not apply at all. Even in that decision, also it has been stated that this is not an offshore supply as title to the goods have passed in India and not outside India. Further decision of the honourable High Court in ITA number 64 of 2014 does not deal with supply of goods. The honourable

ADIT, DEHRADUN vs. M/S. M.I. OVERSEAS LTD., NOIDA

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

151 ITD 79 (Del) does not apply at all. Even in that decision, also it has been stated that this is not an offshore supply as title to the goods have passed in India and not outside India. Further decision of the honourable High Court in ITA number 64 of 2014 does not deal with supply of goods. The honourable

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

151 ITD 79 (Del) does not apply at all. Even in that decision, also it has been stated that this is not an offshore supply as title to the goods have passed in India and not outside India. Further decision of the honourable High Court in ITA number 64 of 2014 does not deal with supply of goods. The honourable

ADIT (INTERNATIONAL TAXATION), DEHRADUN vs. M/S. M.I, OVERSEAS LTD., MUMBAI

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

151 ITD 79 (Del) does not apply at all. Even in that decision, also it has been stated that this is not an offshore supply as title to the goods have passed in India and not outside India. Further decision of the honourable High Court in ITA number 64 of 2014 does not deal with supply of goods. The honourable

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

151 ITD 79 (Del) does not apply at all. Even in that decision, also it has been stated that this is not an offshore supply as title to the goods have passed in India and not outside India. Further decision of the honourable High Court in ITA number 64 of 2014 does not deal with supply of goods. The honourable

ADIT (INTERNATIONAL TAXATION), DEHRADUN vs. M/S. M.I, OVERSEAS LTD., MUMBAI

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

151 ITD 79 (Del) does not apply at all. Even in that decision, also it has been stated that this is not an offshore supply as title to the goods have passed in India and not outside India. Further decision of the honourable High Court in ITA number 64 of 2014 does not deal with supply of goods. The honourable

AKHILESH SINGHAL,RISHIKESH vs. INCOME TAX OFFICER, RISHIKESH

In the result, appeal of the assessee is allowed

penalty order,\nboth dated 07.09.2022 passed u/s 271(1)(b) of the Act for\n Assessment Years 2014-15 & 2015-16 respectively.\nPage | 1\nITA Nos.64, 78 & 79/DDN/2024\n2. As these three appeals are having the issues which are inter-\nlinked, inter-connected and this fact has been admitted by both the\nparties during the course of hearing before

SH.SANJAY RAWAT,,DEHRADUN vs. ACIT, CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] Ita Nos.90, 95 & 104/Ddn/2024 [Assessment Years : 2015-16, 2013-14 & 2013-14] Sanjay Rawat Vs Acit 18S Ats Colony, Central Circle Sahastradhara Road, Dehradun, Dehradun, Uttarakhand-248001 Uttarakhand Pan-Ahopr5244E Appellant Respondent Assessee By Shri Ajay Wadhwa, Adv. Shri Shivam Garg, Adv. & Shri Raghav Sharma, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 11.02.2026 Order Per Manish Agarwal, Am :

271(1(c) of the Act for AY 2013-14 respectively. ITA Nos.90, 95 & 104/DDN/2024 2. At the time of hearing, it was stated that the issues involved in all the captioned appeals are common, interlinked and arising as a result of survey action thus, all these appeals have been heard together and adjudicated by this common order. First

SANJAY RAWAT,DEHRADUN vs. ACIT CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] Ita Nos.90, 95 & 104/Ddn/2024 [Assessment Years : 2015-16, 2013-14 & 2013-14] Sanjay Rawat Vs Acit 18S Ats Colony, Central Circle Sahastradhara Road, Dehradun, Dehradun, Uttarakhand-248001 Uttarakhand Pan-Ahopr5244E Appellant Respondent Assessee By Shri Ajay Wadhwa, Adv. Shri Shivam Garg, Adv. & Shri Raghav Sharma, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 11.02.2026 Order Per Manish Agarwal, Am :

271(1(c) of the Act for AY 2013-14 respectively. ITA Nos.90, 95 & 104/DDN/2024 2. At the time of hearing, it was stated that the issues involved in all the captioned appeals are common, interlinked and arising as a result of survey action thus, all these appeals have been heard together and adjudicated by this common order. First

SANJAY RAWAT,DEHRADUN vs. ACIT CENTRAL CRICLE, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] Ita Nos.90, 95 & 104/Ddn/2024 [Assessment Years : 2015-16, 2013-14 & 2013-14] Sanjay Rawat Vs Acit 18S Ats Colony, Central Circle Sahastradhara Road, Dehradun, Dehradun, Uttarakhand-248001 Uttarakhand Pan-Ahopr5244E Appellant Respondent Assessee By Shri Ajay Wadhwa, Adv. Shri Shivam Garg, Adv. & Shri Raghav Sharma, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 11.02.2026 Order Per Manish Agarwal, Am :

271(1(c) of the Act for AY 2013-14 respectively. ITA Nos.90, 95 & 104/DDN/2024 2. At the time of hearing, it was stated that the issues involved in all the captioned appeals are common, interlinked and arising as a result of survey action thus, all these appeals have been heard together and adjudicated by this common order. First

M/S. UTTARAKHAND PURV SAINIK KALYAN NIGAM LTD.,DEHRADUN vs. ITO, DEHRADUN

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

penalty proceedings u/s 271(1)(c) are bad in law and not sustainable in law under the facts and circumstances of the case in so far as there was neither any willful concealment of income nor did the appellant furnish inaccurate particulars on income. 7. The appellant craves to amend, leave to add, alter, delete, modify or substitute

M/S. UTTARAKHAND PURV SAINIK KALYAN NIGAM LTD.,DEHRADUN vs. ITO, DEHRADUN

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

penalty proceedings u/s 271(1)(c) are bad in law and not sustainable in law under the facts and circumstances of the case in so far as there was neither any willful concealment of income nor did the appellant furnish inaccurate particulars on income. 7. The appellant craves to amend, leave to add, alter, delete, modify or substitute