SHRI VIBHU GROVER,KOTDWARA vs. PCIT, DEHRADUN

In the result appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalvibhu Grover, Pcit, M/S Grover Sales Corporation, Dehradun. Garage Road, Kotdwara, Vs. Pauri-246169 Pan:Agdpg5842R (Appellant) (Respondent) Assessee By Shri Anil Jain, Adv. Department By Shri S.K. Chaterjee, Cit-Dr

reassessment order under Section 148 read with Section 143(3) of the 1961 Act was passed. Addition was not made for the first reason. In the given facts, the assertion by the Revenue that inquiry and verification in re the bank account was not made is ex-facie incorrect. This being the position, this is not a case of failure

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

73 in case of the assessee dated 1 August 2012 wherein it has been held that amount received by the assessee for providing Mud engineering services to an Indian company in connection with the extraction of mineral oils has to be taxed as fees for technical services. He referred to paragraph number [3] where the assessee itself has stated before

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

73 in case of the assessee dated 1 August 2012 wherein it has been held that amount received by the assessee for providing Mud engineering services to an Indian company in connection with the extraction of mineral oils has to be taxed as fees for technical services. He referred to paragraph number [3] where the assessee itself has stated before

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

73 in case of the assessee dated 1 August 2012 wherein it has been held that amount received by the assessee for providing Mud engineering services to an Indian company in connection with the extraction of mineral oils has to be taxed as fees for technical services. He referred to paragraph number [3] where the assessee itself has stated before

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

73 in case of the assessee dated 1 August 2012 wherein it has been held that amount received by the assessee for providing Mud engineering services to an Indian company in connection with the extraction of mineral oils has to be taxed as fees for technical services. He referred to paragraph number [3] where the assessee itself has stated before

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

73 in case of the assessee dated 1 August 2012 wherein it has been held that amount received by the assessee for providing Mud engineering services to an Indian company in connection with the extraction of mineral oils has to be taxed as fees for technical services. He referred to paragraph number [3] where the assessee itself has stated before

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

73 in case of the assessee dated 1 August 2012 wherein it has been held that amount received by the assessee for providing Mud engineering services to an Indian company in connection with the extraction of mineral oils has to be taxed as fees for technical services. He referred to paragraph number [3] where the assessee itself has stated before

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

73 in case of the assessee dated 1 August 2012 wherein it has been held that amount received by the assessee for providing Mud engineering services to an Indian company in connection with the extraction of mineral oils has to be taxed as fees for technical services. He referred to paragraph number [3] where the assessee itself has stated before

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

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 u/s 143(3) of the Act on 08.06.2007 accepting the returned 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

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 u/s 143(3) of the Act on 08.06.2007 accepting the returned 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

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 u/s 143(3) of the Act on 08.06.2007 accepting the returned 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

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 u/s 143(3) of the Act on 08.06.2007 accepting the returned income

BHOPAL SINGH CHAUDHARY,SRINAGAR GARHWAL vs. ITO SRINAGAR, SRINAGAR GARHWAL

Bench: Shri Mahavir Singh & Shri Manish Agarwal

73,000/- by the stamp value authorities, therefore, in terms of section 56(2) of the Act, the assessee should be taxed in the hands of the assessee as Income from other sources and which has escaped assessment. Accordingly, case was re-opened u/s 147 of the Act after obtaining approval from the competent authority and in terms

BHOPAL SINGH CHAUDHARY,DEHRADUN vs. ITO SRINAGAR, SRINAGAR GARHWAL

Bench: Shri Mahavir Singh & Shri Manish Agarwal

73,000/- by the stamp value authorities, therefore, in terms of section 56(2) of the Act, the assessee should be taxed in the hands of the assessee as Income from other sources and which has escaped assessment. Accordingly, case was re-opened u/s 147 of the Act after obtaining approval from the competent authority and in terms

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

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

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