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

E R Per Prashant Maharishi, Accountant Member 1. These are the cross appeals filed by both the parties for several assessment years involving similar grounds of appeal and issues arising out of similar facts and circumstances, therefore, both the parties have similar arguments on the issues, therefore, these appeals are heard together and disposed of by this common order

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

E R Per Prashant Maharishi, Accountant Member 1. These are the cross appeals filed by both the parties for several assessment years involving similar grounds of appeal and issues arising out of similar facts and circumstances, therefore, both the parties have similar arguments on the issues, therefore, these appeals are heard together and disposed of by this common order

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

E R Per Prashant Maharishi, Accountant Member 1. These are the cross appeals filed by both the parties for several assessment years involving similar grounds of appeal and issues arising out of similar facts and circumstances, therefore, both the parties have similar arguments on the issues, therefore, these appeals are heard together and disposed of by this common order

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

E R Per Prashant Maharishi, Accountant Member 1. These are the cross appeals filed by both the parties for several assessment years involving similar grounds of appeal and issues arising out of similar facts and circumstances, therefore, both the parties have similar arguments on the issues, therefore, these appeals are heard together and disposed of by this common order

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

E R Per Prashant Maharishi, Accountant Member 1. These are the cross appeals filed by both the parties for several assessment years involving similar grounds of appeal and issues arising out of similar facts and circumstances, therefore, both the parties have similar arguments on the issues, therefore, these appeals are heard together and disposed of by this common order

DCIT, CIRCLE- 2, INTL. TAXATION, DEHRADUN vs. SCHLUMBERGER ASIA SERVICES LTD., DEHRADUN

In the result, the appeal of the assessee for the Asst Year 2015-16 is partly allowed and that of the revenue is dismissed

Bench: Shri Saktijit Dey & Shri M. Balaganeshita No. 5223/Del/2018 (A. Y.: 2015-16) Schlumberger Asia Services Ltd, Vs. Dcit, 14Th Floor, Tower-C, Building Circle-2, No. 1, Dlf City, Phase-Ii, International Taxation, Gurgaon Dehradun (Appellant) (Respondent) Pan: Aadcs1107J

68,19,422/- c) Reimbursement amounting to Rs 10,84,47,712/-. 4.5. The ld. AO held that the service tax receipts mentioned in a) above should be included as part of gross contractual receipts taxable u/s 44BB of the Act. As far as amount received towards Lost in Hole, the ld. AO by following the decision

SCHLUMBERGER ASIA SERVICES LTD.,DEHRADUN vs. DCIT, CIRCLE- 2, INTL. TAXATION, DEHRADUN

In the result, the appeal of the assessee for the Asst Year 2015-16 is partly allowed and that of the revenue is dismissed

Bench: Shri Saktijit Dey & Shri M. Balaganeshita No. 5223/Del/2018 (A. Y.: 2015-16) Schlumberger Asia Services Ltd, Vs. Dcit, 14Th Floor, Tower-C, Building Circle-2, No. 1, Dlf City, Phase-Ii, International Taxation, Gurgaon Dehradun (Appellant) (Respondent) Pan: Aadcs1107J

68,19,422/- c) Reimbursement amounting to Rs 10,84,47,712/-. 4.5. The ld. AO held that the service tax receipts mentioned in a) above should be included as part of gross contractual receipts taxable u/s 44BB of the Act. As far as amount received towards Lost in Hole, the ld. AO by following the decision

DCIT, CIRCLE- 2, INTL. TAXATION, DEHRADUN vs. SCHLUMBERGER ASIA SERVICES LTD., DEHRADUN

In the result, the appeal of the assessee for the Asst Year 2015-16 is partly allowed and that of the revenue is dismissed

Bench: Shri Saktijit Dey & Shri M. Balaganeshita No. 5223/Del/2018 (A. Y.: 2015-16) Schlumberger Asia Services Ltd, Vs. Dcit, 14Th Floor, Tower-C, Building Circle-2, No. 1, Dlf City, Phase-Ii, International Taxation, Gurgaon Dehradun (Appellant) (Respondent) Pan: Aadcs1107J

68,19,422/- c) Reimbursement amounting to Rs 10,84,47,712/-. 4.5. The ld. AO held that the service tax receipts mentioned in a) above should be included as part of gross contractual receipts taxable u/s 44BB of the Act. As far as amount received towards Lost in Hole, the ld. AO by following the decision

SCHLUMBERGER ASIA SERVICES LTD.,DEHRADUN vs. DCIT, CIRCLE- 2, INTL. TAXATION, DEHRADUN

In the result, the appeal of the assessee for the Asst Year 2015-16 is partly allowed and that of the revenue is dismissed

Bench: Shri Saktijit Dey & Shri M. Balaganeshita No. 5223/Del/2018 (A. Y.: 2015-16) Schlumberger Asia Services Ltd, Vs. Dcit, 14Th Floor, Tower-C, Building Circle-2, No. 1, Dlf City, Phase-Ii, International Taxation, Gurgaon Dehradun (Appellant) (Respondent) Pan: Aadcs1107J

68,19,422/- c) Reimbursement amounting to Rs 10,84,47,712/-. 4.5. The ld. AO held that the service tax receipts mentioned in a) above should be included as part of gross contractual receipts taxable u/s 44BB of the Act. As far as amount received towards Lost in Hole, the ld. AO by following the decision

DCIT, CIRCLE- I, INTERNATIONAL TAXATION, DEHRADUN vs. EXPRESS DRILLING SYSTEMS LLC, DEHRADUN

In the result, cross objection filed by the assessee is partly

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshआ.अ.सं/.I.T.A No.6114/Del/2017 िनधा"रणवष"/Assessment Year: 2009-10 बनाम Dcit, Express Drilling Circle-1, Vs. Systems Llc, International Taxation, C/O Nangia & Co., 1St Floor, Ida, 46, Dehradun, Uttarakhand. E.C. Road, Dehradun, Uttarakhand. Pan No.Aabce6891R अपीलाथ" Appellant ""यथ"/Respondent & Cross Objection No. 13/Del/2018 (In I.T.A No.6114/Del/2017) िनधा"रणवष"/Assessment Year: 2009-10 बनाम Express Drilling Systems Llc, Dcit, Vs. C/O Nangia & Co., Circle-1, 1St Floor, Ida, 46, International Taxation, E.C. Road, Dehradun, Dehradun, Uttarakhand. Uttarakhand. Pan No. Aabce6891R अपीलाथ" Appellant ""यथ"/Respondent

e) records relating to the draft order; (f) evidence collected by, or caused to be collected by, it; and (g) result of any enquiry made, by, or caused to be made by it. (7) The Dispute Resolution Panel may, before issuing any directions referred to in sub-section (5),— (a) make such further enquiry, as it thinks

INTECSEA ASIA PACIFIC SDN BHD,MALAYSIA vs. ACIT, INTERNATIONAL TAXATION, CIRCLE- 1, DEHRADUN

The appeal of the assessee is allowed

Bench: Shri Amit Shukla & Shri B.R.R. Kumarasstt. Year : 2015-16 Intecsea Asia Pacific N Vs. Acit, International Bhd Taxation, Circle-1, Kpmg Salarpuria Knowledge Dehradun City, Orwell Unit 3, 6Th Floor Sy. No. 83/2, Plot 2, Raidurg, Hyderabad 500081 (Appellant) (Respondent)

E R PER AMIT SHUKLA, JM The aforesaid appeal has been filed by the assessee against impugned order dated 22.6.2018 passed by Ld. CIT(A) -2 Noida for the quantum of assessment passed u/s 143(3) / 144C(3)(b) for the assessment year 2015-16. In the grounds of appeal assessee has raised following grounds:- “1.On the facts

BG EXPLORATION & PRODUCTION INDIA LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, DDIT/ADIT (INTERNATIONAL TAXATION), CIRCLE -1, DEHRADUN

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

e-mail facility etc . BGIL has allocated the cost of these assets to its Group companies including Assessee at cost based in allocation methodology decided at the group level . Assessee has capitalized these 21 costs in the book of accounts . During the year , BGIL had allocated an expense o f Rs.80,13,26 ,640/- to the appellant out of which

DCIT, DEHRADUN vs. SH. RAMESH BATTA AS AGENT OF SMT. KAVITA AHUJA, DEHRADUN

In the result, appeal of the Assessee in both the cases are allowed and appeal filed by the Revenue in both the cases are dismissed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalacit, Shri Ramesh Batta Central Circle, 81/210, Kaulagarh Road, Vs. Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Shri Ramesh Batta Dy. Cit, 81/210, Kaulagarh Central Circle, Vs. Road, Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Acit, Shri Ramesh Batta, Central Circle, As Agent Of Smt. Kavita Vs. Dehradun. Ahuja, 81/210, Kaulagarh Road, Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent)

E R PER MANISH AGARWAL, AM: These cross appeals are filed by Assessee and Revenue against the orders passed by the CIT(A), Dehradun dated 03.12.2017 for the Assessment Year 2008-09. 2. Since all the appeals related to one assessment year, therefore, they are tagged together and disposed-off by this consolidated order. First, we shall decide appeal

SHRI RAMESH BATTA,DEHRADUN vs. ACIT, DEHRADUN

In the result, appeal of the Assessee in both the cases are allowed and appeal filed by the Revenue in both the cases are dismissed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalacit, Shri Ramesh Batta Central Circle, 81/210, Kaulagarh Road, Vs. Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Shri Ramesh Batta Dy. Cit, 81/210, Kaulagarh Central Circle, Vs. Road, Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Acit, Shri Ramesh Batta, Central Circle, As Agent Of Smt. Kavita Vs. Dehradun. Ahuja, 81/210, Kaulagarh Road, Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent)

E R PER MANISH AGARWAL, AM: These cross appeals are filed by Assessee and Revenue against the orders passed by the CIT(A), Dehradun dated 03.12.2017 for the Assessment Year 2008-09. 2. Since all the appeals related to one assessment year, therefore, they are tagged together and disposed-off by this consolidated order. First, we shall decide appeal

SHRI RAMESH BATTA,DEHRADUN vs. ACIT, DEHRADUN

In the result, appeal of the Assessee in both the cases are allowed and appeal filed by the Revenue in both the cases are dismissed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalacit, Shri Ramesh Batta Central Circle, 81/210, Kaulagarh Road, Vs. Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Shri Ramesh Batta Dy. Cit, 81/210, Kaulagarh Central Circle, Vs. Road, Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Acit, Shri Ramesh Batta, Central Circle, As Agent Of Smt. Kavita Vs. Dehradun. Ahuja, 81/210, Kaulagarh Road, Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent)

E R PER MANISH AGARWAL, AM: These cross appeals are filed by Assessee and Revenue against the orders passed by the CIT(A), Dehradun dated 03.12.2017 for the Assessment Year 2008-09. 2. Since all the appeals related to one assessment year, therefore, they are tagged together and disposed-off by this consolidated order. First, we shall decide appeal

DCIT, DEHRADUN vs. SHRI RAMESH BATTA, DEHRADUN

In the result, appeal of the Assessee in both the cases are allowed and appeal filed by the Revenue in both the cases are dismissed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalacit, Shri Ramesh Batta Central Circle, 81/210, Kaulagarh Road, Vs. Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Shri Ramesh Batta Dy. Cit, 81/210, Kaulagarh Central Circle, Vs. Road, Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Acit, Shri Ramesh Batta, Central Circle, As Agent Of Smt. Kavita Vs. Dehradun. Ahuja, 81/210, Kaulagarh Road, Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent)

E R PER MANISH AGARWAL, AM: These cross appeals are filed by Assessee and Revenue against the orders passed by the CIT(A), Dehradun dated 03.12.2017 for the Assessment Year 2008-09. 2. Since all the appeals related to one assessment year, therefore, they are tagged together and disposed-off by this consolidated order. First, we shall decide appeal

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DEHRADUN, CROSS ROAD vs. RAJU VERMA, CURZON ROAD, DALANWALA

In the result, the appeal of the assessee is allowed

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh

E R PER M. BALAGANESH, A. M.: 1. The appeal in ITA Nos. 06 & 11/DDN/2024 for AY 2010-11 and 2011-12, arises out of the ld. Commissioner of Income Tax (Appeals)-3, Noida [hereinafter referred to as „ld. CIT(A)‟, in short] dated 10.10.2023 and 1611.2023 against the order of assessment passed u/s 153A(1Xb) r/w sec. 1

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DEHRADUN, CROSS ROAD vs. RAJU VERMA, CURZON ROAD

In the result, the appeal of the assessee is allowed

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh

E R PER M. BALAGANESH, A. M.: 1. The appeal in ITA Nos. 06 & 11/DDN/2024 for AY 2010-11 and 2011-12, arises out of the ld. Commissioner of Income Tax (Appeals)-3, Noida [hereinafter referred to as „ld. CIT(A)‟, in short] dated 10.10.2023 and 1611.2023 against the order of assessment passed u/s 153A(1Xb) r/w sec. 1