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

business of providing services and facilities in connection with an supplying plant and machinery on rent for the purpose of extraction and production of mineral oil. The assessee did not distinguish the stream of its income received from PSC and non-PSC partners. The learned assessing officer held that receipts from PSC contracts are considered to be eligible for claim

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

business of providing services and facilities in connection with an supplying plant and machinery on rent for the purpose of extraction and production of mineral oil. The assessee did not distinguish the stream of its income received from PSC and non-PSC partners. The learned assessing officer held that receipts from PSC contracts are considered to be eligible for claim

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

business of providing services and facilities in connection with an supplying plant and machinery on rent for the purpose of extraction and production of mineral oil. The assessee did not distinguish the stream of its income received from PSC and non-PSC partners. The learned assessing officer held that receipts from PSC contracts are considered to be eligible for claim

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

business of providing services and facilities in connection with an supplying plant and machinery on rent for the purpose of extraction and production of mineral oil. The assessee did not distinguish the stream of its income received from PSC and non-PSC partners. The learned assessing officer held that receipts from PSC contracts are considered to be eligible for claim

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

business of providing services and facilities in connection with an supplying plant and machinery on rent for the purpose of extraction and production of mineral oil. The assessee did not distinguish the stream of its income received from PSC and non-PSC partners. The learned assessing officer held that receipts from PSC contracts are considered to be eligible for claim

G & T RESOURCES (EUROPE) LTD.,NEW DELHI vs. ADIT, DEHRADUN

In the result, the appeal of the assessee is allowed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usita No. 5553/Del/2012 : Asstt. Year: 2004-05 G&T Resources (Europe) Ltd., Vs Adit, C/O F-04 & 05, Triveni Commercial International Taxation, Complex, Sheikh Sarai, Phase-I, Dehradun New Delhi-110017 (Appellant) (Respondent) Pan No. Aabcg9877F Assessee By : None Revenue By : Sh. T. S. Mapwal, Sr. Dr Date Of Hearing: 25.04.2022 Date Of Pronouncement: 29.04.2022 Order Per Dr. B. R. R. Kumar: The Present Appeal Has Been Filed By The Assessee Against The Order Passed By The Ao U/S 143(3) Of The Income Tax Act, 1961 Dated 23.11.2006. 2. The Assessee Has Raised Revised Grounds Of Appeal: “1. That, On The Facts & In The Circumstances Of The Case & In Law, The Learned Ao Has Erred On Facts & In Law In Initiating Proceedings Under Section 148 Read Together With Section 147 Of The Income 1Ax Act, 1961. 2. That In The Absence Of Any New Facts, Other Than The Ones Already On Record Based On Which The Assessment Order Was Passed, Initiating Proceedings Under Section 148 After Expiry Of Four Years Are Bad In Law & Void Abinitio. 3. That, The Learned Ao Having Considered The Facts, Applied The Spirit Of The Boards Instructions As Contained In Notification 1767 In A Speaking Assessment Order Erred In Initiating Proceedings Under Section 148 After The Expiry Of Four Years Merely Because In A Subsequent

147. If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may, subject to the provisions of sections 148 to 153, assess or reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently in the course

SHRI GANGA RAM ADWANI,RISHIKESH vs. DCIT, RISHIKESH

In the result the appeal filed by the assessee is allowed

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastavaasstt. Year 2008-09

business, commission income and income from other sources. He noted that during the course of search and seizure operation conducted u/s 132 of the I.T. Act at the residential premises of Mittal family of M/s. Kanatal Resorts group of cases at Mussoorie Chamba Road, Dehradun, certain documents were found & seized from different premises and statements on oath u/s

SH.SANJAY RAWAT,,DEHRADUN vs. ACIT, CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] Ita Nos.90, 95 & 104/Ddn/2024 [Assessment Years : 2015-16, 2013-14 & 2013-14] Sanjay Rawat Vs Acit 18S Ats Colony, Central Circle Sahastradhara Road, Dehradun, Dehradun, Uttarakhand-248001 Uttarakhand Pan-Ahopr5244E Appellant Respondent Assessee By Shri Ajay Wadhwa, Adv. Shri Shivam Garg, Adv. & Shri Raghav Sharma, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 11.02.2026 Order Per Manish Agarwal, Am :

Income Tax Act, 1961. 5. On the facts and circumstances of the case, the assessment order as affirmed by the CIT(A) is illegal and void-ab-initio as the approval granted u/s 151 is illegal and mechanical in nature. 6. On the facts and circumstances of the case, Ld. CIT(A) has erred both in law as well

SANJAY RAWAT,DEHRADUN vs. ACIT CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] Ita Nos.90, 95 & 104/Ddn/2024 [Assessment Years : 2015-16, 2013-14 & 2013-14] Sanjay Rawat Vs Acit 18S Ats Colony, Central Circle Sahastradhara Road, Dehradun, Dehradun, Uttarakhand-248001 Uttarakhand Pan-Ahopr5244E Appellant Respondent Assessee By Shri Ajay Wadhwa, Adv. Shri Shivam Garg, Adv. & Shri Raghav Sharma, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 11.02.2026 Order Per Manish Agarwal, Am :

Income Tax Act, 1961. 5. On the facts and circumstances of the case, the assessment order as affirmed by the CIT(A) is illegal and void-ab-initio as the approval granted u/s 151 is illegal and mechanical in nature. 6. On the facts and circumstances of the case, Ld. CIT(A) has erred both in law as well

SANJAY RAWAT,DEHRADUN vs. ACIT CENTRAL CRICLE, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] Ita Nos.90, 95 & 104/Ddn/2024 [Assessment Years : 2015-16, 2013-14 & 2013-14] Sanjay Rawat Vs Acit 18S Ats Colony, Central Circle Sahastradhara Road, Dehradun, Dehradun, Uttarakhand-248001 Uttarakhand Pan-Ahopr5244E Appellant Respondent Assessee By Shri Ajay Wadhwa, Adv. Shri Shivam Garg, Adv. & Shri Raghav Sharma, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 11.02.2026 Order Per Manish Agarwal, Am :

Income Tax Act, 1961. 5. On the facts and circumstances of the case, the assessment order as affirmed by the CIT(A) is illegal and void-ab-initio as the approval granted u/s 151 is illegal and mechanical in nature. 6. On the facts and circumstances of the case, Ld. CIT(A) has erred both in law as well

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 was passed without complying with the mandatory conditions of section 147 to 151 of Income Tax Act, 1961. 2. That in any case and in any view of the matter, Ld. Pr. CIT has erred in law in assuming jurisdiction and passing the impugned order u/s 263, is bad in law and against the facts and circumstances

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

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

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 of land

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

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

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 of land

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

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

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 of land

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

income declared by the Assessee. 6. Later this assessment was sought to be reopened by the revenue. For this assessment, the ld AO issued first notice u/s 148 of the Act later on 17.08.2010. This notice is enclosed at page 5 of the PB. The reasons for reopening the assessment was to deny deduction u/s 80IC

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

income declared by the Assessee. 6. Later this assessment was sought to be reopened by the revenue. For this assessment, the ld AO issued first notice u/s 148 of the Act later on 17.08.2010. This notice is enclosed at page 5 of the PB. The reasons for reopening the assessment was to deny deduction u/s 80IC

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

income declared by the Assessee. 6. Later this assessment was sought to be reopened by the revenue. For this assessment, the ld AO issued first notice u/s 148 of the Act later on 17.08.2010. This notice is enclosed at page 5 of the PB. The reasons for reopening the assessment was to deny deduction u/s 80IC

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

income declared by the Assessee. 6. Later this assessment was sought to be reopened by the revenue. For this assessment, the ld AO issued first notice u/s 148 of the Act later on 17.08.2010. This notice is enclosed at page 5 of the PB. The reasons for reopening the assessment was to deny deduction u/s 80IC