NATIONAL OILWELL VARCO PTE. LTD.,MUMBAI vs. DCIT (INTERNATIONAL TAXATION), CI9RCLE-2, DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

reassessment cannot be read into Section 144C more particularly when the provisions of Section 153 are excluded by the non-obstante clause in section 144C(13) and hence the proceedings are not barred by limitation. Per contra, it has been contended by the learned senior counsels appearing for the respondent(s)/assessees that the outer time limit under Section

NATIONAL OILWELL VARCO PTE. LTD. (FORMERLY KNOWN AS VARCO INTERNATIONAL PTE LTD.),MUMBAI vs. DCIT (INTERNATIONAL TAXATION), CIRCLE-2, DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

reassessment cannot be read into Section 144C more particularly when the provisions of Section 153 are excluded by the non-obstante clause in section 144C(13) and hence the proceedings are not barred by limitation. Per contra, it has been contended by the learned senior counsels appearing for the respondent(s)/assessees that the outer time limit under Section

NATIONAL OIL WELL VARCO PTE. LTD (FORMERLY KNOWN AS VARCO INTERNATIONAL PTE. LTD),MAHARASHTRA vs. THE DEPUTY DIRECTOR OF INCOME TAX CIRCLE-1( INTERNATIONAL TAXATION ), DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

reassessment cannot be read into Section 144C more particularly when the provisions of Section 153 are excluded by the non-obstante clause in section 144C(13) and hence the proceedings are not barred by limitation. Per contra, it has been contended by the learned senior counsels appearing for the respondent(s)/assessees that the outer time limit under Section

SIME DARBY ENGINEERING SDN BHD,DELHI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRCLE-1, DEHRADUN

In the result, appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

reassessment cannot be read into Section 144C more particularly when the provisions of Section 153 are excluded by the non-obstante clause in section 144C(13) and hence the proceedings are not barred by limitation. Per contra, it has been contended by the learned senior counsels appearing for the respondent(s)/assessees that the outer time limit under Section

SIME DARBY ENGINEERING SDN BHD,GURGAON vs. DCIT (INTERNATIONAL TAXATION), CIRCLE-2, DEHRADUN

In the result, appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

reassessment cannot be read into Section 144C more particularly when the provisions of Section 153 are excluded by the non-obstante clause in section 144C(13) and hence the proceedings are not barred by limitation. Per contra, it has been contended by the learned senior counsels appearing for the respondent(s)/assessees that the outer time limit under Section

SIME DARBY ENGINEERING SDNBHD,MALAYSIA vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION ) CIRCLE-1, DEHRADUN

In the result, appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

reassessment cannot be read into Section 144C more particularly when the provisions of Section 153 are excluded by the non-obstante clause in section 144C(13) and hence the proceedings are not barred by limitation. Per contra, it has been contended by the learned senior counsels appearing for the respondent(s)/assessees that the outer time limit under Section

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DEHRADUN vs. M/S. SHARDA EXPORTS, HARIDWAR

In the result, appeal of the Assessee in ITA No

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

37,925/- with a profit of Rs. 15,69,73,241/- including duty draw back claim of M/s Sharda Export Vs. the ACIT Rs. 2,72,99,429/-. The Assessee firm claimed deduction u/s 80IC of the Act @100% of its profits and accordingly, filed Nil income in the return of income. The original assessment was completed

M/S. SHARDA EXPORTS,MEERUT vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE , DEHRADUN

In the result, appeal of the Assessee in ITA No

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

37,925/- with a profit of Rs. 15,69,73,241/- including duty draw back claim of M/s Sharda Export Vs. the ACIT Rs. 2,72,99,429/-. The Assessee firm claimed deduction u/s 80IC of the Act @100% of its profits and accordingly, filed Nil income in the return of income. The original assessment was completed

M/S. SHARDA EXPORTS,MEERUT vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the Assessee in ITA No

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

37,925/- with a profit of Rs. 15,69,73,241/- including duty draw back claim of M/s Sharda Export Vs. the ACIT Rs. 2,72,99,429/-. The Assessee firm claimed deduction u/s 80IC of the Act @100% of its profits and accordingly, filed Nil income in the return of income. The original assessment was completed

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DEHRADUN vs. M/S. SHARDA EXPORTS, HARIDWAR

In the result, appeal of the Assessee in ITA No

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

37,925/- with a profit of Rs. 15,69,73,241/- including duty draw back claim of M/s Sharda Export Vs. the ACIT Rs. 2,72,99,429/-. The Assessee firm claimed deduction u/s 80IC of the Act @100% of its profits and accordingly, filed Nil income in the return of income. The original assessment was completed

RITU SINGHAL,DEHRADUN vs. DCIT/ACIT , CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

37 of the Income Tax Act, 1961:\nAny expenditure (not being expenditure of the nature described in sections 30 to 36 and\nnot being in the nature of capital expenditure or personal expenses of the assessee),\nlaid out or expended wholly and exclusively for the purposes of the business or\nprofession shall be allowed in computing the income chargeable under

M/S. R.B. ENTERPRISES,DEHRADUN vs. DCIT, DEHRADUN

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra(Through Video Conferencing)

37,86) 38,41,085) has been made by the assessee it is clear that the excess carry forward amounting to Ra. 2,03,07,171/ remained un- explanation and untaxed during the course of finalizing assessment order, in the year under consideration. 3 Keeping in view all the above facts, I have reason to believe that income chargeable

M/S. R.B. ENTERPRISES,DEHRADUN vs. DCIT, DEHRADUN

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra(Through Video Conferencing)

37,86) 38,41,085) has been made by the assessee it is clear that the excess carry forward amounting to Ra. 2,03,07,171/ remained un- explanation and untaxed during the course of finalizing assessment order, in the year under consideration. 3 Keeping in view all the above facts, I have reason to believe that income chargeable

DCIT, CENTRAL CIRCLE, DEHRADUN vs. R.B. ENTERPRISES, DEHRADUN

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra(Through Video Conferencing)

37,86) 38,41,085) has been made by the assessee it is clear that the excess carry forward amounting to Ra. 2,03,07,171/ remained un- explanation and untaxed during the course of finalizing assessment order, in the year under consideration. 3 Keeping in view all the above facts, I have reason to believe that income chargeable

OMWATI,DEHRADUN vs. PR.CIT, DEHRADUN

In the result, the appeal of the assessee is allowed

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshsmt. Omwati Pr. Cit W/O Sh. Dariyav Singh Dehradun 171/1, Vasant Vihar, Vs. Dehradun Pan-Aanpw 6438K (Appellant) (Respondent)

1. That having regard to the facts and circumstances of the case, Ld. Pr. CIT. has erred in law and on facts in assuming jurisdiction u/s 263 which is bad in law inter alia for this reason that the reassessment order dated 21.03.2016 which is sought to be revised u/s 263 itself was invalid on various grounds as mentioned below

MASCOT FASTNERS PRIVATE LIMITED,UTTARAKHAND vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI, -

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

Bench: Shri M. Balaganesh & Shri Satbeer Singh Godara(Through Video Conferencing) M/S. Mascot Fastners Pvt. Vs. National Faceless Ltd, Assessment Centre, Plot No. B-155, Eldeco, Sidcul, Delhi Industrial Park, Sitarganj, Udham Singh Nagar, 262 403 (Appellant) (Respondent) Pan: Aabcm4504H Assessee By : Shri Atul Ninawat, Partner Revenue By: Shri A. S. Rana, Sr. Dr Date Of Hearing 18/03/2025 Date Of Pronouncement 02/04/2025

1. The initiation of re-assessment proceedings is bad in law as well as facts of the case and the re-assessment order passed u/s 147 should be quashed. 2. The Ld. CIT(A) has erred in law as well as facts of the case in upholding the re-assessment order passed by the Ld. AO even though

SHRI ABHISHEK JOSHI,DEHRADUN vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX , DEHRADUN

In the result, the appeal of the assessee is allowed

Bench: Sh. Saktijit Dey & Shri M. Balaganeshshri Abhishek Joshi, Vs. The Pr. Cit, C/O. Parimal Patet, Gk Patet & Dehradun Co, 14 Abhishek Tower, Subhash Road, Dehradun (Appellant) (Respondent) Pan: Ajopj4300M Assessee By : Dr. Rakesh Gupta, Adv Shri Somil Aggarwal, Adv Revenue By: Shri N. S. Jangpangi, Cit Dr Date Of Hearing 26/07/2023 Date Of Pronouncement 15/09/2023

reassessment passed u/s 143(3) rws 147 of the Income-tax Act, 1961 (hereinafter referred to as „the Act‟) dated 30.10.2018 by the Assessing Officer, ITO, Ward-1(1), Dehradun (hereinafter referred to as „ld. AO‟). 2. The assessee has raised the following grounds of appeal:- “1. That having regard to the facts and circumstances of the case, Ld. PCIT

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DEHRADUN vs. M/S. SHARDA EXPORTS, HARIDWAR

In the result, the appeal of the Assessee is allowed and the appeal of the revenue is dismissed

Bench: Sh. C. N. Prasad & Shri M. Balaganesh(Through Video Conferencing) M/S. Sharda Exports, Vs. Ito, C/O. Sh. Jitendra Kumar Gupta, Ward-1(3)(3), 219, Railway Road, Meerut Haridawar (Appellant) (Respondent) Pan: Aayfs1694N Dcit, Vs. M/S. Sharda Exports, Central Circle, C/O. Sh. Jitendra Kumar Gupta, Dehradun 219, Railway Road, Meerut (Appellant) (Respondent) Pan: Aayfs1694N

37,925/- with a profit of Rs. 15,69,73,241/- including duty draw back claim of Rs. 2,72,99,429/-. The Assessee firm claimed ITA No.43/DDN/2022 M/s. Sharda Exports deduction u/s 80IC of the Act @100% of its profits and accordingly, filed Nil income in the return of income. The original assessment was completed