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3 results for “penalty u/s 271”+ Section 36(1)(viii)clear

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Key Topics

Section 44B6Section 143(3)3Section 44D3Disallowance3Section 144C(5)2Transfer Pricing2Reassessment2Reopening of Assessment2Comparables/TP

SCHLUMBERGER ASIA SERVICES LTD.,GURGAON vs. DDIT, DEHRADUN

In the result, the appeal filed by the Revenue is dismissed and the appeal filed by the assessee is partly allowed

ITA 6437/DEL/2014[2011-12]Status: DisposedITAT Dehradun05 May 2022AY 2011-12

Bench: Shri R.K. Panda & Shri C.N. Prasad[Assessment Year: 2011-12] Schlumberger Asia Services Deputy Director Of Income Tax Limited, (International Taxation), 14Th Floor, Tower C, Building Dehradun No.1, Dlf City, Phase Ii, Gurgaon-122002 Pan-Aadcs1107J Assessee Revenue [Assessment Year: 2011-12] Deputy Director Of Income Tax Schlumberger Asia Services (International Taxation), Limited, Dehradun 14Th Floor, Tower C, Building No.1, Dlf City, Phase Ii, Gurgaon-122002 Pan- Aadcs1107J Revenue Assessee Assessee By Sh. Salil Kapoor, Adv. Ms. Ananya Kappor & Ms. Soumya Singh, Adv. Revenue By Sh. T.S.Mapwal, Sr.Dr

Section 143(3)Section 44BSection 44DSection 9

viii), the benefit of section 44BB cannot be availed by the assessee. In other “fees for technical service ” and earned from activities in connection with exploration and production of mineral oil are includible in the revenue chargeable to tax under section 44BB of the Act. 2. The activities of the appellant are NOT “general in nature” and are directly

2
TP Method2

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

ITA 13/DDN/2022[2015-16]Status: DisposedITAT Dehradun27 Dec 2022AY 2015-16

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

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. Mayak Kumar, JCIT, DR
Section 143(3)Section 144C(5)

271(1 )(c) of the Act. 20.3 The Appellant submits that each grounds of appeal are without prejudice to one another. 20.4 The Appellant craves leave to add, alter, amend, substitute and /or modify in any manner whatsoever all or any of the foregoing grounds of objections at or before the hearing of the appeal.” 3. The assessee has raised

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

ITA 47/DDN/2022[2018-19]Status: DisposedITAT Dehradun27 Dec 2022AY 2018-19

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

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. Mayak Kumar, JCIT, DR
Section 143(3)Section 144C(5)

271(1 )(c) of the Act. 20.3 The Appellant submits that each grounds of appeal are without prejudice to one another. 20.4 The Appellant craves leave to add, alter, amend, substitute and /or modify in any manner whatsoever all or any of the foregoing grounds of objections at or before the hearing of the appeal.” 3. The assessee has raised