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19 results for “section 68”+ Section 131(3)clear

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Key Topics

Section 153C30Section 44B16Addition to Income14Section 153A13Section 143(3)12Section 9(1)(vii)8Section 16Section 92D6Section 686Transfer Pricing

RAJ BALA MITTAL,HARDWAR vs. ITO, WARD-3, HARDWAR

In the result, the appeal of the assessee is allowed

ITA 5629/DEL/2018[2013-14]Status: DisposedITAT Dehradun23 Jun 2023AY 2013-14

Bench: Him For Examination

3 AY: 2013-14 5. It is not in dispute that the assessee has furnished the name and address of the lender, bank statement of the lender and confirmation of the lender before the lower authorities. The lender is situated in Ghaziabad, which is far away from the place of assessee and, hence, explanation given by the assessee that

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

ITA 6126/DEL/2017[2013-14]Status: DisposedITAT Dehradun15 Sept 2023AY 2013-14

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

6
Comparables/TP6
Reassessment5
For Appellant: Shri P. J. Pardiwalla, Sr. AdvFor Respondent: Shri Mayank Kumar, JCIT, DR
Section 143(3)Section 44BSection 9(1)(vii)

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

ITA 6173/DEL/2017[2014-15]Status: DisposedITAT Dehradun15 Sept 2023AY 2014-15

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

For Appellant: Shri P. J. Pardiwalla, Sr. AdvFor Respondent: Shri Mayank Kumar, JCIT, DR
Section 143(3)Section 44BSection 9(1)(vii)

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

ITA 5305/DEL/2018[2015-16]Status: DisposedITAT Dehradun15 Sept 2023AY 2015-16

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

For Appellant: Shri P. J. Pardiwalla, Sr. AdvFor Respondent: Shri Mayank Kumar, JCIT, DR
Section 143(3)Section 44BSection 9(1)(vii)

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

ITA 5223/DEL/2018[2015-16]Status: DisposedITAT Dehradun15 Sept 2023AY 2015-16

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

For Appellant: Shri P. J. Pardiwalla, Sr. AdvFor Respondent: Shri Mayank Kumar, JCIT, DR
Section 143(3)Section 44BSection 9(1)(vii)

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

ACIT, UTTRAKHAND vs. M/S. UTTARANCHAL JAL VIDYUT NIGAM LTD., DEHRADUN

In the result, the appeal filed by the Revenue is dismissed

ITA 736/DEL/2017[2012-13]Status: DisposedITAT Dehradun24 Dec 2021AY 2012-13

Bench: Shri R.K. Panda & Shri Challa Nagendra Prasadassessment Year: 2012-13 Acit, Vs. Uttaranchal Jal Vidyut Circle-2, Nigam Ltd., 13-A, Subhash Road, Ujjwal, Maharani Bagh, Uttarakhand. Gms Road, Dehradun. Pan: Aaacu6672R (Appellant) (Respondent) Assessee By : Dr. Rakesh Gupta, Advocate & Shri Somil Aggarwal, Advocate Revenue By : Smt. Poonam Sharma, Sr. Dr Date Of Hearing : 22.12.2021 Date Of Pronouncement : 24.12.2021 Order Per R.K. Panda, Am: This Appeal Filed By The Revenue Is Directed Against The Order Dated 29Th December, 2016 Of The Cit(A), Dehradun, Relating To Assessment Year 2012-13. 2. The Only Effective Ground Raised By The Revenue Reads As Under:- “1. The Ld.Cit(A) Has Erred In Law & On Facts By Allowing Depreciation On Assets For Which The Actual Cost As Per Section 43(1) Of The Income Tax Act, 1961 Was Nil. 2. The Order Of The Ld.Cit(Appeals) Be Set Aside & That Of The Assessing Officer Be Restored.”

For Appellant: Dr. Rakesh Gupta, Advocate &For Respondent: Smt. Poonam Sharma, Sr. DR
Section 143(3)Section 2Section 32Section 43Section 43(1)

3) of the Income Tax Act, 1961 (hereinafter called 'the Act') on 22nd December 2006 assessing total income of the assessee at Rs 40,67,51,498/-. Being aggrieved, the assessee filed an appeal before Ld. CIT (A). The Ld. first appellate authority, vide order dated 30th December 2008, allowed part relief. Assessee filed a further appeal before this Tribunal

CHARANJEET LAL ARORA,HARIDWAR vs. ACIT CIRCLE 1(3) 1 HARIDWAR, HARIDWAR

In the result, the appeal of the Assessee is allowed

ITA 211/DDN/2024[2017-18]Status: DisposedITAT Dehradun29 Jul 2025AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 211/Ddn/2024 (A.Y 2017-18) Sh. Charanjeet Lal Arora Vs Acit M/S Amit Agencies, Village Sarai, Circe (1)(3)(1) Near Sabji Mandi, Jwalapur, Haridwar Haridwar-249407, Uttarakhand Uttarakhand Pan: Aanpa9280F Appellant Respondent Assessee By Sh. Salil Aggarwal & Sh. Shailesh Gupta, Advs Revenue By Sh. A. S. Rana, Sr. Dr Date Of Hearing 08/07/2025 Date Of Pronouncement 29/07/2025 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-Addl/Jcit (A)-1, Surat (‘Ld.

Section 131Section 143(3)Section 68

section 143(3) of the Income Tax Act, 1961 ('Act' for short)by making an addition of Rs. 8,00,000/- on account of unexplained credit u/s. 68 of the Act. Aggrieved by the assessment order dated 2 Charanjeet Lal Arora Vs. ACIT 16/12/2019, the Assessee preferred an Appeal before the Ld. CIT(A). The Ld. CIT(A) vide

PAL MINERAL INDUSTRIES (P) LIMITED,HALDWANI vs. DC/ACIT, CENTRAL CIRCLE, HALDWANI, HALDWANI

ITA 106/DDN/2025[2013-2014]Status: DisposedITAT Dehradun12 Mar 2026AY 2013-2014

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

Section 143(3)Section 153ASection 153CSection 250

section 153Aof the Income Tax Act, 1961 in the ease of M/s. DEEPAK BULDERS & ENGINEERS INDIA PVT. LTD. A search n/s 132 of Income Tax Act was conducted on an Entry operator Sanjay Jain along with his facilitators and some of his beneficiaries who were found to be generating cash against bogus billing of cement and other such items

PAL MINERAL INDUSTRIES (P) LIMITED,HALDWANI vs. DC/ACIT, CENTRAL CIRCLE, HALDWANI, HALDWANI

ITA 105/DDN/2025[2014-2015]Status: DisposedITAT Dehradun12 Mar 2026AY 2014-2015

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

Section 143(3)Section 153ASection 153CSection 250

section 153Aof the Income Tax Act, 1961 in the ease of M/s. DEEPAK BULDERS & ENGINEERS INDIA PVT. LTD. A search n/s 132 of Income Tax Act was conducted on an Entry operator Sanjay Jain along with his facilitators and some of his beneficiaries who were found to be generating cash against bogus billing of cement and other such items

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

ITA 85/DDN/2024[2015-16]Status: DisposedITAT Dehradun12 Mar 2026AY 2015-16

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

Section 132Section 143(3)Section 153ASection 153A(1)Section 153CSection 250

section 153Aof the Income Tax Act, 1961 in the ease of M/s. DEEPAK BULDERS & ENGINEERS INDIA PVT. LTD. A search n/s 132 of Income Tax Act was conducted on an Entry operator Sanjay Jain along with his facilitators and some of his beneficiaries who were found to be generating cash against bogus billing of cement and other such items

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

ITA 83/DDN/2024[2013-14]Status: DisposedITAT Dehradun12 Mar 2026AY 2013-14

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

Section 132Section 143(3)Section 153ASection 153A(1)Section 153CSection 250

section 153Aof the Income Tax Act, 1961 in the ease of M/s. DEEPAK BULDERS & ENGINEERS INDIA PVT. LTD. A search n/s 132 of Income Tax Act was conducted on an Entry operator Sanjay Jain along with his facilitators and some of his beneficiaries who were found to be generating cash against bogus billing of cement and other such items

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

ITA 84/DDN/2024[2014-15]Status: DisposedITAT Dehradun12 Mar 2026AY 2014-15

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

Section 132Section 143(3)Section 153ASection 153A(1)Section 153CSection 250

section 153Aof the Income Tax Act, 1961 in the ease of M/s. DEEPAK BULDERS & ENGINEERS INDIA PVT. LTD. A search n/s 132 of Income Tax Act was conducted on an Entry operator Sanjay Jain along with his facilitators and some of his beneficiaries who were found to be generating cash against bogus billing of cement and other such items

ACIT, CIRCLE- II, INTERNATIONAL TAXATION, DEHRADUN vs. WEATHERFORD OIL TOOLS ME LTD., DEHRADUN

ITA 7477/DEL/2017[2013-14]Status: DisposedITAT Dehradun28 Apr 2025AY 2013-14

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Salil Kapoor, Sh. Anil ChachraFor Respondent: Sh. Mithun Shete, Sr. DR
Section 1Section 92D

68,74,954 as the income attributable to the Appellants PE from offshore supply of goods and thereby confirming the addition of INR 34,20,203. Ground No. 2 That on the facts and in the circumstances of the case and in law the Ld CIT(A) erred in arbitrary applying the 3 ITA Nos. 7334, 7477 & 7848/Del./2017

ACIT, CIRCLE- II, INTERNATIONAL TAXATION , DEHRADUN vs. WEATHERFORD OIL TOOLS M.E. LTD., DEHRADUN

ITA 5696/DEL/2018[2015-16]Status: DisposedITAT Dehradun28 Apr 2025AY 2015-16

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Salil Kapoor, Sh. Anil ChachraFor Respondent: Sh. Mithun Shete, Sr. DR
Section 1Section 92D

68,74,954 as the income attributable to the Appellants PE from offshore supply of goods and thereby confirming the addition of INR 34,20,203. Ground No. 2 That on the facts and in the circumstances of the case and in law the Ld CIT(A) erred in arbitrary applying the 3 ITA Nos. 7334, 7477 & 7848/Del./2017

ACIT, CIRCLE- II, INTERNATIONAL TAXATION, DEHRADUN vs. WEATHERFORD OIL TOOLS M.E. LTD., DEHRADUN

ITA 417/DEL/2018[2014-15]Status: DisposedITAT Dehradun28 Apr 2025AY 2014-15

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Salil Kapoor, Sh. Anil ChachraFor Respondent: Sh. Mithun Shete, Sr. DR
Section 1Section 92D

68,74,954 as the income attributable to the Appellants PE from offshore supply of goods and thereby confirming the addition of INR 34,20,203. Ground No. 2 That on the facts and in the circumstances of the case and in law the Ld CIT(A) erred in arbitrary applying the 3 ITA Nos. 7334, 7477 & 7848/Del./2017

WEATHERFORD OIL TOOLS M E LTD.,DEHRADUN vs. DCIT, CIRCLE- 2, INTL. TAXATION, DEHRADUN

ITA 7334/DEL/2017[2013-14]Status: DisposedITAT Dehradun28 Apr 2025AY 2013-14

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Salil Kapoor, Sh. Anil ChachraFor Respondent: Sh. Mithun Shete, Sr. DR
Section 1Section 92D

68,74,954 as the income attributable to the Appellants PE from offshore supply of goods and thereby confirming the addition of INR 34,20,203. Ground No. 2 That on the facts and in the circumstances of the case and in law the Ld CIT(A) erred in arbitrary applying the 3 ITA Nos. 7334, 7477 & 7848/Del./2017

WEATHERFORD OIL TOOLS M.E. LTD.,NOIDA vs. DCIT, CIRCLE- 2, INTERNATIONAL TAXATION, DEHRADUN

ITA 7848/DEL/2017[2014-15]Status: DisposedITAT Dehradun28 Apr 2025AY 2014-15

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Salil Kapoor, Sh. Anil ChachraFor Respondent: Sh. Mithun Shete, Sr. DR
Section 1Section 92D

68,74,954 as the income attributable to the Appellants PE from offshore supply of goods and thereby confirming the addition of INR 34,20,203. Ground No. 2 That on the facts and in the circumstances of the case and in law the Ld CIT(A) erred in arbitrary applying the 3 ITA Nos. 7334, 7477 & 7848/Del./2017

WEATHERFORD OIL TOOLS ME LTD.,DEHRADUN vs. ACIT, CIRCLE- II, INTERNATIONAL TAXATION, DEHRADUN

ITA 5647/DEL/2018[2015-16]Status: DisposedITAT Dehradun28 Apr 2025AY 2015-16

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Salil Kapoor, Sh. Anil ChachraFor Respondent: Sh. Mithun Shete, Sr. DR
Section 1Section 92D

68,74,954 as the income attributable to the Appellants PE from offshore supply of goods and thereby confirming the addition of INR 34,20,203. Ground No. 2 That on the facts and in the circumstances of the case and in law the Ld CIT(A) erred in arbitrary applying the 3 ITA Nos. 7334, 7477 & 7848/Del./2017

UTTRANCHAL SOCIAL DEVELOPMENT CENTRE PRIVATE LIMITED ,DEHRADUN vs. INCOME TAX OFFICER , DEHRADUN

Appeal is partly allowed

ITA 150/DDN/2024[2017-18]Status: DisposedITAT Dehradun25 Apr 2025AY 2017-18

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Anil Jain, AdvFor Respondent: Sh. A. S. Rana, Sr. DR
Section 143(3)Section 68

3 Uttranchal Social Development Centre Pvt. Ltd. argued that the AO has not pointed out any mistake/irregularity from them. This is undisputed fact that appellant company has clearly shown the cash withdrawal from its bank account during the FY 2016-17 and has explained that the cash amount of Rs. 10945000 was re-deposited in the bank in the wake