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

4 of the appeal are identical to ground number 1 – 7 of the appeal of the learned assessing officer for assessment year 2006 – 07. There is no change in the facts and circumstances of the case, their arguments are also same, and therefore for the reasons stated therein, we dismiss these grounds of appeal. 35. In view of this appeal

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

4 of the appeal are identical to ground number 1 – 7 of the appeal of the learned assessing officer for assessment year 2006 – 07. There is no change in the facts and circumstances of the case, their arguments are also same, and therefore for the reasons stated therein, we dismiss these grounds of appeal. 35. In view of this appeal

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

4 of the appeal are identical to ground number 1 – 7 of the appeal of the learned assessing officer for assessment year 2006 – 07. There is no change in the facts and circumstances of the case, their arguments are also same, and therefore for the reasons stated therein, we dismiss these grounds of appeal. 35. In view of this appeal

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

4 of the appeal are identical to ground number 1 – 7 of the appeal of the learned assessing officer for assessment year 2006 – 07. There is no change in the facts and circumstances of the case, their arguments are also same, and therefore for the reasons stated therein, we dismiss these grounds of appeal. 35. In view of this appeal

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

4 of the appeal are identical to ground number 1 – 7 of the appeal of the learned assessing officer for assessment year 2006 – 07. There is no change in the facts and circumstances of the case, their arguments are also same, and therefore for the reasons stated therein, we dismiss these grounds of appeal. 35. In view of this appeal

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

4 of the appeal are identical to ground number 1 – 7 of the appeal of the learned assessing officer for assessment year 2006 – 07. There is no change in the facts and circumstances of the case, their arguments are also same, and therefore for the reasons stated therein, we dismiss these grounds of appeal. 35. In view of this appeal

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

4 of the appeal are identical to ground number 1 – 7 of the appeal of the learned assessing officer for assessment year 2006 – 07. There is no change in the facts and circumstances of the case, their arguments are also same, and therefore for the reasons stated therein, we dismiss these grounds of appeal. 35. In view of this appeal

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), DEHRADUN, DEHRADUN vs. CHAKRATA FIRST AND ASSOCIATES, JAIPUR

Appeal is dismissed

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh(Through Video Conferencing) Assessment Year: 2017-18 Acit, Vs. Chakrata First & Circle-1(1)(1), Associates, C/O- Amit Tak 41 Dehradun Sanjay Marg, Hathori Fort, Jaipur, Rajasthan Pan: Aalfc2896B (Appellant) (Respondent) Assessee By Sh. S.K. Ahuja, Ar Department By Sh. Amar Pal Singh, Sr. Dr

41 Dehradun Sanjay Marg, Hathori Fort, Jaipur, Rajasthan PAN: AALFC2896B (Appellant) (Respondent) Assessee by Sh. S.K. Ahuja, AR Department by Sh. Amar Pal Singh, Sr. DR Date of hearing 18.03.2025 Date of pronouncement 23.05.2025 ORDER PER SATBEER SINGH GODARA, JM This assessee’s appeal for assessment year 2017-18, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal

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

41, 44 & 45/DDN/2022 M/s Sharda Export Vs. the ACIT IN THE INCOME TAX APPELLATE TRIBUNAL DELHI DELHI BENCH ‘DEHRADUN/’ NEW DELHI BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER I.T.A. No. 40/DDN/2022 (A.Y 2006-07) I.T.A. No. 41/DDN/2022 (A.Y 2007-08) M/s Sharda Exports Vs ACIT C/o. Sh. Jitenera Kumar Gupta Central Circle, Income

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

41, 44 & 45/DDN/2022 M/s Sharda Export Vs. the ACIT IN THE INCOME TAX APPELLATE TRIBUNAL DELHI DELHI BENCH ‘DEHRADUN/’ NEW DELHI BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER I.T.A. No. 40/DDN/2022 (A.Y 2006-07) I.T.A. No. 41/DDN/2022 (A.Y 2007-08) M/s Sharda Exports Vs ACIT C/o. Sh. Jitenera Kumar Gupta Central Circle, Income

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

41, 44 & 45/DDN/2022 M/s Sharda Export Vs. the ACIT IN THE INCOME TAX APPELLATE TRIBUNAL DELHI DELHI BENCH ‘DEHRADUN/’ NEW DELHI BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER I.T.A. No. 40/DDN/2022 (A.Y 2006-07) I.T.A. No. 41/DDN/2022 (A.Y 2007-08) M/s Sharda Exports Vs ACIT C/o. Sh. Jitenera Kumar Gupta Central Circle, Income

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

41, 44 & 45/DDN/2022 M/s Sharda Export Vs. the ACIT IN THE INCOME TAX APPELLATE TRIBUNAL DELHI DELHI BENCH ‘DEHRADUN/’ NEW DELHI BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER I.T.A. No. 40/DDN/2022 (A.Y 2006-07) I.T.A. No. 41/DDN/2022 (A.Y 2007-08) M/s Sharda Exports Vs ACIT C/o. Sh. Jitenera Kumar Gupta Central Circle, Income

ATUL KUMAR AGRAWAL,MANPUR ROAD, KASHIPUR vs. NATIONAL E-ASSESSMENT CENTRE, NEW DELHI

In the result, appeal of the assessee is partly allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year: 2018-19] Mr. Atul Kumar Agarwal Vs National Prop.M/S. R.K. Industries, E-Assessment Centre, Manpur Road, Kashipur, New Delhi U.S. Nagar, Uttarakhand- 244713 Pan-Aaopa9970H Appellant Respondent Assessee By Shri Deepak Joshi,Adv. & Shri Rudra Pratab, Adv. Revenue By Shri Amar Pal Singh, Sr.Dr Date Of Hearing 13.11.2025 Date Of Pronouncement 16.01.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 04.12.2024 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Nfac/2017-18/10235798 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 15.03.2023 Passed U/S 147 R.W.S. 144B Of The Act Pertaining To Assessment Year 2018-19. 2. Brief Facts Of The Case Are That Assessee Filed His Return Of Income On 15.08.2018, Declaring Total Income At Inr 5,81,560/-. The Case Of The Assessee Was Re-Opened U/S 147 Of The Act. Accordingly, Notice U/S 148 Was Issued On 30.03.2022, In Response To Which The Assessee Filed Return Of Income On 03.05.2022, Declaring Same Income As Was Declared In The Return Filed U/S 139(1) Of The Act. Thereafter Notice U/S 143(2) Of The Act Was Issued Followed By Notices U/S 142(1) Alongwith Questionnaires. In Response Filed Replies From Time To Time. After Considering The Submissions Made By The Assessee, Ao Completed The Assessment Vide Order Dated 15.03.2023 Passed U/S 147 R.W.S. 144B Of The Act Wherein The Total Income Was Assessed At Inr 54,23,320/-.

4. In the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in not appreciating that the Ld. AO has not discharged its burden of proof as the Ld. AO has neither pointed out a single error or discrepancy in documents/evidences the submitted by the Appellant nor conducted any independent investigation

NAINITAL DISTRICT CO-OPERATIVE BANK,HALDWANI vs. ACIT, CIRCLE-1, HALDWANI

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

4. That the impugned order is bad in law and not in consonance with facts, and against the principles of natural justice. 5. We have heard the Ld. DR and perused the materials available on record. The assessee is a regional rural bank and had filed its return of income for the A.Y. 2011- 12 on 30.09.2011 in the status

NAINITAL DISTRICT CO-OPERATIVE BANK,HALDWANI vs. DCIT, CIRCLE-1, HALDWANI

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

4. That the impugned order is bad in law and not in consonance with facts, and against the principles of natural justice. 5. We have heard the Ld. DR and perused the materials available on record. The assessee is a regional rural bank and had filed its return of income for the A.Y. 2011- 12 on 30.09.2011 in the status

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

41 days. Considering the reason adduced in the condonation petition, we are inclined to condone the delay in the interest of substantial justice and admit the appeal of the assessee for adjudication. 3. The assessee has raised the following grounds of appeal:- M/s. Mascot Fastners Pvt. Ltd “1. The initiation of re-assessment proceedings is bad in law as well

METRO FROZEN FRUIT & VEGETABLES PVT. LTD.,ROORKEE vs. DCIT, CIRCLE, HARIDWAR

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

Bench: Shri R.K. Panda & Shri N. K. Choudhry[Assessment Year: 2009-10] Metro Frozen Fruits & Dcit, Vegetables Pvt. Ltd. Circle Haridwar, Plot No.22, Rajpur, Vs Uttarakhan Bhagwanpur, Roorkee, Uttrakhand Pan-Aaecm4521F Assessee Revenue Assessee By Sh. Piyush Kuchhal, Fca Revenue By Ms. Poonam Sharma Cit-Dr Date Of Hearing 23.02.2022 Date Of Pronouncement 08.03.2022 Order Per R.K. Panda, Am, This Appeal Filed By The Assessee Is Directed Against The Order Dated 24.01.2019 Of The Learned Cit(A), Dehradun, Relating To Assessment Year 2009-10. 2. The Grounds Raised By The Assessee Are As Under:-

Section 143(3) of the Act. 6. On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law rejecting the contention of the assessee that approval having been granted in a mechanical manner is bad in law, hence the consequential proceedings u/s 147 of the Act are illegal and liable

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

4. Since the grounds are common in both the appeals they are being adjudicated together. 5. Ground No. 1 Reassessment u/s 148 –not pressed 6. Ground No. 2 to 7-Transfer Pricing issue: Intra group services: 7. During year, the intra-group services received by the assessee from the Associated Enterprises amounting to Rs.229,61,81,619/- on account

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

4. Since the grounds are common in both the appeals they are being adjudicated together. 5. Ground No. 1 Reassessment u/s 148 –not pressed 6. Ground No. 2 to 7-Transfer Pricing issue: Intra group services: 7. During year, the intra-group services received by the assessee from the Associated Enterprises amounting to Rs.229,61,81,619/- on account