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

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

set aside and the order of AO be restored. 5. The appellant craves leave to add or amend any other more ground of appeal as state above as and when needs for doing so may arise. 5. Both the parties invite our attention to the learned CIT(A)’s lower appellate discussion quashing the impugned reopening itself as under

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

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

set aside and the order of AO be restored. 5. The appellant craves leave to add or amend any other more ground of appeal as state above as and when needs for doing so may arise. 5. Both the parties invite our attention to the learned CIT(A)’s lower appellate discussion quashing the impugned reopening itself as under

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

147 is reproduced as under:- “Provided that where an assessment under sub-section (3) of section 143 or this section has been made for the relevant assessment year, no action shall be taken under this section after the expiry of four years from the end of the relevant assessment year, unless any income chargeable to tax has escaped assessment

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

147 is reproduced as under:- “Provided that where an assessment under sub-section (3) of section 143 or this section has been made for the relevant assessment year, no action shall be taken under this section after the expiry of four years from the end of the relevant assessment year, unless any income chargeable to tax has escaped assessment

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

147 is reproduced as under:- “Provided that where an assessment under sub-section (3) of section 143 or this section has been made for the relevant assessment year, no action shall be taken under this section after the expiry of four years from the end of the relevant assessment year, unless any income chargeable to tax has escaped assessment

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

147 is reproduced as under:- “Provided that where an assessment under sub-section (3) of section 143 or this section has been made for the relevant assessment year, no action shall be taken under this section after the expiry of four years from the end of the relevant assessment year, unless any income chargeable to tax has escaped assessment

INCOME TAX OFFICER, WARD-1(1)(3), DEHRADUN, AAYKAR BHAWAN, SUBHASH ROAD, DEHRADUN vs. UTTARAKHAND PURV SAINIK KALYAN NIGAM LIMITED, STATION SUB AREA

In the result, appeal of the assessee is allowed

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

set aside. Thus, sought for allowing the appeal. 6. Per contra, the ld. AR submitted that the issue involved in the present appeal is squarely covered in assessee’s own case for A.Y. 2014-15, therefore submitted that grounds of appeal of the Revenue is devoid of merit and sought for dismissal of the appeal 7. We have heard

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]

set aside the impugned assessment order being barred by limitation as per Section 153 of the Act r.w. Section 144 of the Act. 5. Further, in so far as initial Interim Order granted by Hon'ble Supreme Court dated 22/09/2023 and the dissenting Judgment by the Hon'ble Supreme Court in the case of ACIT Vs. Shelf Drilling Ron Tappmeyer

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]

set aside the impugned assessment order being barred by limitation as per Section 153 of the Act r.w. Section 144 of the Act. 5. Further, in so far as initial Interim Order granted by Hon'ble Supreme Court dated 22/09/2023 and the dissenting Judgment by the Hon'ble Supreme Court in the case of ACIT Vs. Shelf Drilling Ron Tappmeyer

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]

set aside the impugned assessment order being barred by limitation as per Section 153 of the Act r.w. Section 144 of the Act. 5. Further, in so far as initial Interim Order granted by Hon'ble Supreme Court dated 22/09/2023 and the dissenting Judgment by the Hon'ble Supreme Court in the case of ACIT Vs. Shelf Drilling Ron Tappmeyer

NATIONAL OILWELL VARCO PTE. LTD.,MUMBAI vs. DCIT (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]

set aside the impugned assessment order being barred by limitation as per Section 153 of the Act r.w. Section 144 of the Act. 5. Further, in so far as initial Interim Order granted by Hon'ble Supreme Court dated 22/09/2023 and the dissenting Judgment by the Hon'ble Supreme Court in the case of ACIT Vs. Shelf Drilling Ron Tappmeyer

NATIONAL OILWELL VARCO PTE LTD.,MUMBAI vs. DCIT (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]

set aside the impugned assessment order being barred by limitation as per Section 153 of the Act r.w. Section 144 of the Act. 5. Further, in so far as initial Interim Order granted by Hon'ble Supreme Court dated 22/09/2023 and the dissenting Judgment by the Hon'ble Supreme Court in the case of ACIT Vs. Shelf Drilling Ron Tappmeyer

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]

set aside the impugned assessment order being barred by limitation as per Section 153 of the Act r.w. Section 144 of the Act. 5. Further, in so far as initial Interim Order granted by Hon'ble Supreme Court dated 22/09/2023 and the dissenting Judgment by the Hon'ble Supreme Court in the case of ACIT Vs. Shelf Drilling Ron Tappmeyer

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]

set aside the impugned assessment order being barred by limitation as per Section 153 of the Act r.w. Section 144 of the Act. 5. Further, in so far as initial Interim Order granted by Hon'ble Supreme Court dated 22/09/2023 and the dissenting Judgment by the Hon'ble Supreme Court in the case of ACIT Vs. Shelf Drilling Ron Tappmeyer

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]

set aside the impugned assessment order being barred by limitation as per Section 153 of the Act r.w. Section 144 of the Act. 5. Further, in so far as initial Interim Order granted by Hon'ble Supreme Court dated 22/09/2023 and the dissenting Judgment by the Hon'ble Supreme Court in the case of ACIT Vs. Shelf Drilling Ron Tappmeyer