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

271 (l)(c) of the Act 11. The Ld AO has erred on facts and in law in holding that the assessee is required to comply with the provisions of section 44AB of the Act by furnishing the audited accounts by the specified date and initiating penalty proceeding under section 27IB of the Act.” 52. Ground number

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

271 (l)(c) of the Act 11. The Ld AO has erred on facts and in law in holding that the assessee is required to comply with the provisions of section 44AB of the Act by furnishing the audited accounts by the specified date and initiating penalty proceeding under section 27IB of the Act.” 52. Ground number

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

271 (l)(c) of the Act 11. The Ld AO has erred on facts and in law in holding that the assessee is required to comply with the provisions of section 44AB of the Act by furnishing the audited accounts by the specified date and initiating penalty proceeding under section 27IB of the Act.” 52. Ground number

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

271 (l)(c) of the Act 11. The Ld AO has erred on facts and in law in holding that the assessee is required to comply with the provisions of section 44AB of the Act by furnishing the audited accounts by the specified date and initiating penalty proceeding under section 27IB of the Act.” 52. Ground number

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

271 (l)(c) of the Act 11. The Ld AO has erred on facts and in law in holding that the assessee is required to comply with the provisions of section 44AB of the Act by furnishing the audited accounts by the specified date and initiating penalty proceeding under section 27IB of the Act.” 52. Ground number

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

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

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

M/S THDC INDIA LIMITED, RISHIKESH,RISHIKESH vs. PCIT, DEHRADUN, DEHRADUN

In the result, appeal of the assessee is partly allowed

57 ITR 521 (SC) H.M. Kashiparekh\n& Co. Ltd. v. CIT [1960] 39 ITR 706 (Bombay) State Bank of Travencore v. CIT\n[1986] 24 Taxman 337/158 ITR 102 (SC) and the Supreme Court held in this\nPage | 9\nITA No.69/DDN/2024\ncase that the question, whether there was real accrual of income to the\nassessee Co. in respect

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

In the result, the appeal of the assessee is partly allowed

Bench: Shri R.K. Panda & Shri V.P. Raoassessment Years: 2016-17

u/s. 144C(5)of the Act for the assessment year 2016-17. The assessee has raised the following grounds : Ground No. 1: Erroneous disallowance of payment made towards intra-group services by Appellant to its Associated Enterprise (“AE”) 1.1. The learned Transfer Pricing Officer ("TPO") / AO / DRP grossly erred in law and on facts by making an upward transfer pricing

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

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

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

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