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8 results for “reassessment”+ Section 125clear

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Key Topics

Section 44B14Section 914Section 2637Addition to Income7Section 144C6Section 143(3)2

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

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

ITA 5584/DEL/2013[2010-11]Status: DisposedITAT Dehradun08 Jun 2021AY 2010-11

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

125,698,442/– being taxed at the normal rate and income of ₹ 332,333,572/– is to be taxed at the rate of 10%. Thus, he considered the sum of ₹ 332,333,572 as income characterized as fees for technical services or royalty. Against draft assessment order no objections were filed before the learned dispute resolution panel and therefore

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

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

ITA 3072/DEL/2012[2009-10]Status: DisposedITAT Dehradun08 Jun 2021AY 2009-10

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

125,698,442/– being taxed at the normal rate and income of ₹ 332,333,572/– is to be taxed at the rate of 10%. Thus, he considered the sum of ₹ 332,333,572 as income characterized as fees for technical services or royalty. Against draft assessment order no objections were filed before the learned dispute resolution panel and therefore

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

ITA 3045/DEL/2013[2006-07]Status: DisposedITAT Dehradun08 Jun 2021AY 2006-07

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

125,698,442/– being taxed at the normal rate and income of ₹ 332,333,572/– is to be taxed at the rate of 10%. Thus, he considered the sum of ₹ 332,333,572 as income characterized as fees for technical services or royalty. Against draft assessment order no objections were filed before the learned dispute resolution panel and therefore

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

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

ITA 2956/DEL/2013[2006-07]Status: DisposedITAT Dehradun08 Jun 2021AY 2006-07

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

125,698,442/– being taxed at the normal rate and income of ₹ 332,333,572/– is to be taxed at the rate of 10%. Thus, he considered the sum of ₹ 332,333,572 as income characterized as fees for technical services or royalty. Against draft assessment order no objections were filed before the learned dispute resolution panel and therefore

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

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

ITA 5583/DEL/2013[2007-08]Status: DisposedITAT Dehradun08 Jun 2021AY 2007-08

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

125,698,442/– being taxed at the normal rate and income of ₹ 332,333,572/– is to be taxed at the rate of 10%. Thus, he considered the sum of ₹ 332,333,572 as income characterized as fees for technical services or royalty. Against draft assessment order no objections were filed before the learned dispute resolution panel and therefore

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

ITA 5565/DEL/2013[2010-11]Status: DisposedITAT Dehradun08 Jun 2021AY 2010-11

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

125,698,442/– being taxed at the normal rate and income of ₹ 332,333,572/– is to be taxed at the rate of 10%. Thus, he considered the sum of ₹ 332,333,572 as income characterized as fees for technical services or royalty. Against draft assessment order no objections were filed before the learned dispute resolution panel and therefore

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

ITA 5564/DEL/2013[2007-08]Status: DisposedITAT Dehradun08 Jun 2021AY 2007-08

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

125,698,442/– being taxed at the normal rate and income of ₹ 332,333,572/– is to be taxed at the rate of 10%. Thus, he considered the sum of ₹ 332,333,572 as income characterized as fees for technical services or royalty. Against draft assessment order no objections were filed before the learned dispute resolution panel and therefore

DCIT, CIRCLE- I, INTERNATIONAL TAXATION, DEHRADUN vs. EXPRESS DRILLING SYSTEMS LLC, DEHRADUN

In the result, cross objection filed by the assessee is partly

ITA 6114/DEL/2017[2009-10]Status: DisposedITAT Dehradun26 Sept 2023AY 2009-10

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshआ.अ.सं/.I.T.A No.6114/Del/2017 िनधा"रणवष"/Assessment Year: 2009-10 बनाम Dcit, Express Drilling Circle-1, Vs. Systems Llc, International Taxation, C/O Nangia & Co., 1St Floor, Ida, 46, Dehradun, Uttarakhand. E.C. Road, Dehradun, Uttarakhand. Pan No.Aabce6891R अपीलाथ" Appellant ""यथ"/Respondent & Cross Objection No. 13/Del/2018 (In I.T.A No.6114/Del/2017) िनधा"रणवष"/Assessment Year: 2009-10 बनाम Express Drilling Systems Llc, Dcit, Vs. C/O Nangia & Co., Circle-1, 1St Floor, Ida, 46, International Taxation, E.C. Road, Dehradun, Dehradun, Uttarakhand. Uttarakhand. Pan No. Aabce6891R अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 144CSection 234BSection 40

125 taxmann.com 262 (Delhi) where the facts before the Honourble Delhi High Court shows that assessee, a wholly owned subsidiary of Headstrong Services LLC, USA, had filed its return of income declaring income of 5 I.T.A.No.6114/Del/2017 & CO No. 13/Del/2018 Rs. 30,64,480/- for the relevant assessment year. Thereafter, revised return of income was filed on 30th January