MOHAN PAL,HALDWANI, NAINITAL vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, HALDWANI, ACIT - DCIT, CENTRAL CIRCLE, HALDWANI

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

Section 153C action initiated for AYs' 2000-01 to 2003-04would not sustain. It was this position in law as enunciated in that decision which came to be reiterated by our Court in Index Securities. 54. In any case, Abhisar Buildwell, in our considered opinion, is a decision which conclusively lays to rest any doubt that could have been

MOHAN PAL,HALDWANI, NAINITAL vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, HALDWANI, ACIT-DCIT, CENTRAL CIRCLE, HALDWANI

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

Section 153C action initiated for AYs' 2000-01 to 2003-04would not sustain. It was this position in law as enunciated in that decision which came to be reiterated by our Court in Index Securities. 54. In any case, Abhisar Buildwell, in our considered opinion, is a decision which conclusively lays to rest any doubt that could have been

MOHAN PAL,HALDWANI, NAINITAL vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, HALDWANI, ACIT - DCIT, CENTRAL CIRCLE, HALDWANI

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

Section 153C action initiated for AYs' 2000-01 to 2003-04would not sustain. It was this position in law as enunciated in that decision which came to be reiterated by our Court in Index Securities. 54. In any case, Abhisar Buildwell, in our considered opinion, is a decision which conclusively lays to rest any doubt that could have been

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)

reassessment order erroneous and prejudicial to the interest of the Revenue. 6. We find that the assessee had claimed exemption u/s 54B of the Act amounting to Rs 37,75,000/- in respect of amount paid to Smt. Sangeeta Singh for purchase of agricultural land vide agreement to sell cum with possession deed dated 30.07.2009. In Page

SANJAY BANSAL,DEHRADUN vs. DCIT CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Sh. Anil Chaturvedi & Sh. Challa Nagendra Prasad

54 of the paper book and pointed to the noting made by AO dated 30.03.2015 wherein it is noted that the draft order was submitted for approval u/s 153D of the Act and the approval was received vide Letter No.1158 on the same date. He thereafter pointed to the copy of the assessment order passed u/s 153A r.w.s

SANJAY BANSAL,DEHRADUN vs. DCIT CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Sh. Anil Chaturvedi & Sh. Challa Nagendra Prasad

54 of the paper book and pointed to the noting made by AO dated 30.03.2015 wherein it is noted that the draft order was submitted for approval u/s 153D of the Act and the approval was received vide Letter No.1158 on the same date. He thereafter pointed to the copy of the assessment order passed u/s 153A r.w.s

SANJAY BANSAL,DEHRADUN vs. DCIT CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Sh. Anil Chaturvedi & Sh. Challa Nagendra Prasad

54 of the paper book and pointed to the noting made by AO dated 30.03.2015 wherein it is noted that the draft order was submitted for approval u/s 153D of the Act and the approval was received vide Letter No.1158 on the same date. He thereafter pointed to the copy of the assessment order passed u/s 153A r.w.s

SANJAY BANSAL,NEW DELHI vs. DCIT CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Sh. Anil Chaturvedi & Sh. Challa Nagendra Prasad

54 of the paper book and pointed to the noting made by AO dated 30.03.2015 wherein it is noted that the draft order was submitted for approval u/s 153D of the Act and the approval was received vide Letter No.1158 on the same date. He thereafter pointed to the copy of the assessment order passed u/s 153A r.w.s

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

reassessment proceedings, no arguments were advanced before us, therefore this ground of appeal is dismissed. 37. Ground number 2 – 5 is with respect to the taxability of revenue from offshore supply of imported material. The parties submitted that facts are identical to ground number 2 of the appeal of the assessee for assessment year 2006 – 07 and their arguments

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

reassessment proceedings, no arguments were advanced before us, therefore this ground of appeal is dismissed. 37. Ground number 2 – 5 is with respect to the taxability of revenue from offshore supply of imported material. The parties submitted that facts are identical to ground number 2 of the appeal of the assessee for assessment year 2006 – 07 and their arguments

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

reassessment proceedings, no arguments were advanced before us, therefore this ground of appeal is dismissed. 37. Ground number 2 – 5 is with respect to the taxability of revenue from offshore supply of imported material. The parties submitted that facts are identical to ground number 2 of the appeal of the assessee for assessment year 2006 – 07 and their arguments

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

reassessment proceedings, no arguments were advanced before us, therefore this ground of appeal is dismissed. 37. Ground number 2 – 5 is with respect to the taxability of revenue from offshore supply of imported material. The parties submitted that facts are identical to ground number 2 of the appeal of the assessee for assessment year 2006 – 07 and their arguments

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

reassessment proceedings, no arguments were advanced before us, therefore this ground of appeal is dismissed. 37. Ground number 2 – 5 is with respect to the taxability of revenue from offshore supply of imported material. The parties submitted that facts are identical to ground number 2 of the appeal of the assessee for assessment year 2006 – 07 and their arguments

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

reassessment proceedings, no arguments were advanced before us, therefore this ground of appeal is dismissed. 37. Ground number 2 – 5 is with respect to the taxability of revenue from offshore supply of imported material. The parties submitted that facts are identical to ground number 2 of the appeal of the assessee for assessment year 2006 – 07 and their arguments

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

reassessment proceedings, no arguments were advanced before us, therefore this ground of appeal is dismissed. 37. Ground number 2 – 5 is with respect to the taxability of revenue from offshore supply of imported material. The parties submitted that facts are identical to ground number 2 of the appeal of the assessee for assessment year 2006 – 07 and their arguments

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

reassessment. Ground No. 2: Erroneous disallowance of payment made towards intra-group services by Appellant to its Associated Enterprise (“AE”) 2.1 The learned Transfer Pricing Officer ("TPO") / AO / DRP grossly erred in law and on facts by making an upward transfer pricing adjustment of Rs.219,44,33,564 in total towards international transactions pertaining to payment of management service

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

reassessment. Ground No. 2: Erroneous disallowance of payment made towards intra-group services by Appellant to its Associated Enterprise (“AE”) 2.1 The learned Transfer Pricing Officer ("TPO") / AO / DRP grossly erred in law and on facts by making an upward transfer pricing adjustment of Rs.219,44,33,564 in total towards international transactions pertaining to payment of management service

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

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

section 147 of Income Tax Act, 1961 (Negi) Dy. Commissioner of Income Tax Central Circle, Dehra Dun 3.4 Adjudication of the grounds of appeal requires perusal of bare facts, which are as follows: 4 | P a g e ITA Nos.3500 & 3501/Del/2017 and i. The appellant is a registered partnership firm, engaged in the business of development, purchase and sale