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

68,050/- by making an addition to the returned income of Rs.10,93,796/- on account of sale of spares adjustment to the returned income. 7. Aggrieved, the Appellant filed an appeal before ITAT raising the above said grounds dated 02.01.2017. 8. Heard the arguments of both the parties and perused the material available on record. Reasons recorded

D BALI INFRASTRUCTURE AND DEVELOPMENT LTD.,KASHIPUR (U.S.NAGAR) vs. DCIT, CIRCLE-2, KASHIPUR, KASHIPUR

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri M. Balaganesh & Shri Satbeer Singh Godara(Through Video Conferencing) D Bali Infrastructure & Vs. Dcit, Developers Ltd., Circle-2, Kashra No. 151, Apna Ghar Kashipur Village-Gangapur, Kundeshwari Road, Kashipur, Dist. Utham Singh Nagar-244713 (Appellant) (Respondent) Pan: Aadcd3599D Assessee By : None Revenue By: Shri Amar Pal Singh, Sr. Dr Date Of Hearing 18/03/2025 Date Of Pronouncement 18/03/2025

68 of the Act in the sum of Rs 1,80,00,000/- in the facts and circumstances of the instant case 3. None appeared on behalf of the assessee despite issuance of notice. Hence we proceed to dispose of this appeal on hearing the Learned DR and based on materials available on record. We find that assessee had filed

REENA VERMA,HARIDWAR vs. ITO, WARD-1(3)(5), ROORKEE

In the result, the appeal of the assessee stands partly allowed as above

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

68,600/- paid to the State Excise department as unexplained. The AO also noticed that the assessee, licensee of country liquor appointed by the 4 Reena Verma State Govt., had picked up her allotted quota of liquor from India Glycols Ltd. by making cash payment of Rs.40,09,123/- in contravention to section

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

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

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

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

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

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

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 ME LTD., DEHRADUN

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

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

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

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

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

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- 3, NAINITAL vs. KUMAON MANDAL VIKAS NIGAM LTD., NAINITAL

In the result, both appeals of the Revenue are partly allowed as above

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

68,009/- instead of returned loss of (-) Rs.76,05,926/- (ii) Disallowance of employees’ contribution in EPF and ECGI under section 36(1)(va) r.w.s.2(24)(x) and 43B of the Act. (iii) Disallowance of interest of Rs.50,50,442/- on Government loans/ advances (iv) Disallowance of shortage/shrinkage of stock of petroleum products sold from petrol pumps

ACIT, NAINITAL vs. M/S. KUMAON MANDAL VIKAS NIGAM LTD., NAINITAL

In the result, both appeals of the Revenue are partly allowed as above

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

68,009/- instead of returned loss of (-) Rs.76,05,926/- (ii) Disallowance of employees’ contribution in EPF and ECGI under section 36(1)(va) r.w.s.2(24)(x) and 43B of the Act. (iii) Disallowance of interest of Rs.50,50,442/- on Government loans/ advances (iv) Disallowance of shortage/shrinkage of stock of petroleum products sold from petrol pumps

KUNWAR TOSEEN,KOTDWAR DISTT. PAURI GARHWAL vs. INCOME TAX OFFICER, KOTDWAR

In the result, both the appeals are allowed for statistical purposes

Bench: Shri Vimal Kumar & Shri Brajesh Kumar Singh

Sections 142(1) dated 26.09.2022, 01.11.2022, letter dated 22.12.2022 and show- cause-notices dated 29.12.2022, 15.02.2023, 27.02.2023 and 10.03.2023, no compliance was made by Assessee. Ld. AO passed assessment order dated 14.03.2023. In pursuance to assessment order dated 14.03.2023. Ld. AO passed penalty order dated 05.09.2023. 3. Against assessment order dated 14.03.2023 and penalty order 05.09.2023, the assessee filed

KUNWAR TOSEEN,KOTDWAR DISTT. PAURI GARHWAL vs. INCOME TAX OFFICER , KOTDWAR

In the result, both the appeals are allowed for statistical purposes

Bench: Shri Vimal Kumar & Shri Brajesh Kumar Singh

Sections 142(1) dated 26.09.2022, 01.11.2022, letter dated 22.12.2022 and show- cause-notices dated 29.12.2022, 15.02.2023, 27.02.2023 and 10.03.2023, no compliance was made by Assessee. Ld. AO passed assessment order dated 14.03.2023. In pursuance to assessment order dated 14.03.2023. Ld. AO passed penalty order dated 05.09.2023. 3. Against assessment order dated 14.03.2023 and penalty order 05.09.2023, the assessee filed

SH. SURENDER KUMAR CHAWLA,RUDRAPUR vs. ACIT, CC-, HALDWANI, HALDWANI

In the result, assessee’s appeals; ITA No

Bench: BEFORESHRI CHALLA NAGENDRA PRASAD (Judicial Member), SHRI AVDHESH KUMAR MISHRA (Accountant Member)

142(2A) is invalid as the special audit was conducted against the provisions of law. 5. The learned assessing officer as also learned CIT(A) have erred in making and confirming addition of Rs.19,25,249/- as unexplained cash credit u/s 68 of the Income Tax Act, 1961 being alleged net negative cash. 6. The learned assessing officer as also

SH. SURENDER KUMAR CHAWLA,RUDRAPUR vs. ACIT, CC, , HALDWANI

In the result, assessee’s appeals; ITA No

Bench: BEFORESHRI CHALLA NAGENDRA PRASAD (Judicial Member), SHRI AVDHESH KUMAR MISHRA (Accountant Member)

142(2A) is invalid as the special audit was conducted against the provisions of law. 5. The learned assessing officer as also learned CIT(A) have erred in making and confirming addition of Rs.19,25,249/- as unexplained cash credit u/s 68 of the Income Tax Act, 1961 being alleged net negative cash. 6. The learned assessing officer as also

SH. SURINDER KUMAR CHAWLA,RUDRAPUR vs. ACIT,CC, HALDWANI, HALDWANI

In the result, assessee’s appeals; ITA No

Bench: BEFORESHRI CHALLA NAGENDRA PRASAD (Judicial Member), SHRI AVDHESH KUMAR MISHRA (Accountant Member)

142(2A) is invalid as the special audit was conducted against the provisions of law. 5. The learned assessing officer as also learned CIT(A) have erred in making and confirming addition of Rs.19,25,249/- as unexplained cash credit u/s 68 of the Income Tax Act, 1961 being alleged net negative cash. 6. The learned assessing officer as also

SH.SURENDER KUMAR CHAWLA,RUDRAPUR vs. ACIT , CC, HALDWANI, HALDWANI

In the result, assessee’s appeals; ITA No

Bench: BEFORESHRI CHALLA NAGENDRA PRASAD (Judicial Member), SHRI AVDHESH KUMAR MISHRA (Accountant Member)

142(2A) is invalid as the special audit was conducted against the provisions of law. 5. The learned assessing officer as also learned CIT(A) have erred in making and confirming addition of Rs.19,25,249/- as unexplained cash credit u/s 68 of the Income Tax Act, 1961 being alleged net negative cash. 6. The learned assessing officer as also

SH.SURENDER KUMAR CHAWLA,DEHRADUN vs. ACIT, CC, DEHRADUN, HALDWANI

In the result, assessee’s appeals; ITA No

Bench: BEFORESHRI CHALLA NAGENDRA PRASAD (Judicial Member), SHRI AVDHESH KUMAR MISHRA (Accountant Member)

142(2A) is invalid as the special audit was conducted against the provisions of law. 5. The learned assessing officer as also learned CIT(A) have erred in making and confirming addition of Rs.19,25,249/- as unexplained cash credit u/s 68 of the Income Tax Act, 1961 being alleged net negative cash. 6. The learned assessing officer as also