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

143 (3) read with Section 144C (3) of The Income Tax Act dated 14 May 2013 was partly allowed. Both the parties are aggrieved with that order and therefore are in appeal. 61. The learned AO has raised the following grounds of appeal in ITA No. 5565/Del/2012 for the Assessment Year 2010-11:- “1. Whether on the facts

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

143 (3) read with Section 144C (3) of The Income Tax Act dated 14 May 2013 was partly allowed. Both the parties are aggrieved with that order and therefore are in appeal. 61. The learned AO has raised the following grounds of appeal in ITA No. 5565/Del/2012 for the Assessment Year 2010-11:- “1. Whether on the facts

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

143 (3) read with Section 144C (3) of The Income Tax Act dated 14 May 2013 was partly allowed. Both the parties are aggrieved with that order and therefore are in appeal. 61. The learned AO has raised the following grounds of appeal in ITA No. 5565/Del/2012 for the Assessment Year 2010-11:- “1. Whether on the facts

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

143 (3) read with Section 144C (3) of The Income Tax Act dated 14 May 2013 was partly allowed. Both the parties are aggrieved with that order and therefore are in appeal. 61. The learned AO has raised the following grounds of appeal in ITA No. 5565/Del/2012 for the Assessment Year 2010-11:- “1. Whether on the facts

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

143 (3) read with Section 144C (3) of The Income Tax Act dated 14 May 2013 was partly allowed. Both the parties are aggrieved with that order and therefore are in appeal. 61. The learned AO has raised the following grounds of appeal in ITA No. 5565/Del/2012 for the Assessment Year 2010-11:- “1. Whether on the facts

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

143 (3) read with Section 144C (3) of The Income Tax Act dated 14 May 2013 was partly allowed. Both the parties are aggrieved with that order and therefore are in appeal. 61. The learned AO has raised the following grounds of appeal in ITA No. 5565/Del/2012 for the Assessment Year 2010-11:- “1. Whether on the facts

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

143(3)/144C(a) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 11.11.2016 by the Assessing Officer, DCIT, International Taxation, Circle-2, Dehradun for AY 2014-15 and 16.01.2018 by the ACIT, International Taxation, Circle-2, Dehradun (hereinafter referred to as ‘ld. AO’). 2. Identical issues are involved in all these appeals and hence they

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

143(3)/144C(a) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 11.11.2016 by the Assessing Officer, DCIT, International Taxation, Circle-2, Dehradun for AY 2014-15 and 16.01.2018 by the ACIT, International Taxation, Circle-2, Dehradun (hereinafter referred to as ‘ld. AO’). 2. Identical issues are involved in all these appeals and hence they

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

143(3)/144C(a) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 11.11.2016 by the Assessing Officer, DCIT, International Taxation, Circle-2, Dehradun for AY 2014-15 and 16.01.2018 by the ACIT, International Taxation, Circle-2, Dehradun (hereinafter referred to as ‘ld. AO’). 2. Identical issues are involved in all these appeals and hence they

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

143(3)/144C(a) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 11.11.2016 by the Assessing Officer, DCIT, International Taxation, Circle-2, Dehradun for AY 2014-15 and 16.01.2018 by the ACIT, International Taxation, Circle-2, Dehradun (hereinafter referred to as ‘ld. AO’). 2. Identical issues are involved in all these appeals and hence they

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)

68 taxmann.com 143)]; • DIT vs. Jindal Drilling & Industries Ltd. [(2009) (182 Taxman 59)]; • Siem Offshore Inc, In re. [(2011) 12 taxmann.com 374] 12. Apart from above, he also relied upon the following decisions in support of its clam that consideration received for services rendered in connection with prospecting, extraction or production of mineral oils shall be taxable under section

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

143(2) of the Act was issued. During scrutiny assessment, the Assessing Officer made a reference to the office of Transfer Pricing Officer (TPO) in relation to the international transaction between the respondent- assessee and its Associated Enterprise (AE). Draft assessment order under section 1440(1) of the Act was passed on 31st December, 2010 and the respondent- assessee

DCIT, DEHRADUN vs. INTECSEA ASIA PACIFIC SDN BHD, HYDERABAD

The appeal of the assessee is allowed

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 152/Ddn/2025 : Asstt. Year: 2016-17 Ita No. 153/Ddn/2025 : Asstt. Year: 2018-19 Dcit, Vs Intecsea Asia Pacific Sdn Bhd, 13A, Subhash Road, Income Road No. 11, Barijara Hills, Tax Officer, Dehradun-248001 Hyderabad-500034 (Appellant) (Respondent) Pan No. Aabci3002L Assessee By : Sh. Siddesh Choudhary, Adv. Revenue By : Sh. Mohan Lal Joshi, Sr. Dr Date Of Hearing: 13.01.2026 Date Of Pronouncement: 13.01.2026 Order Per Satbeer Singh Godara: These Revenue’S Twin Appeals

68 taxmann.com 143)];  DIT vs. Jindal Drilling & Industries Ltd. [(2009) (182 Taxman 59)];  Siem Offshore Inc, In re. [(2011) 12 taxmann.com 374] 12. Apart from above, he also relied upon the following decisions in support of its clam that consideration received for services rendered in connection with prospecting, extraction or production of mineral oils shall be taxable under section

DCIT, DEHRADUN vs. INTECSEA ASIA PACIFIC SDN BHD, HYDERABAD

The appeal of the assessee is allowed

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 152/Ddn/2025 : Asstt. Year: 2016-17 Ita No. 153/Ddn/2025 : Asstt. Year: 2018-19 Dcit, Vs Intecsea Asia Pacific Sdn Bhd, 13A, Subhash Road, Income Road No. 11, Barijara Hills, Tax Officer, Dehradun-248001 Hyderabad-500034 (Appellant) (Respondent) Pan No. Aabci3002L Assessee By : Sh. Siddesh Choudhary, Adv. Revenue By : Sh. Mohan Lal Joshi, Sr. Dr Date Of Hearing: 13.01.2026 Date Of Pronouncement: 13.01.2026 Order Per Satbeer Singh Godara: These Revenue’S Twin Appeals

68 taxmann.com 143)];  DIT vs. Jindal Drilling & Industries Ltd. [(2009) (182 Taxman 59)];  Siem Offshore Inc, In re. [(2011) 12 taxmann.com 374] 12. Apart from above, he also relied upon the following decisions in support of its clam that consideration received for services rendered in connection with prospecting, extraction or production of mineral oils shall be taxable under section

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

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

143(3)/144C Oil Tools ME A.Y. 2015-16 Appeal No. 93/CIT(A)- (3)(b) Ltd. 2 /2017-18/Noida Dated 22.06.2018 2. Heard both the parties at length. Case file perused. We proceed assessment year wise for the sake of convenience and brevity. A.Y. 2013-14 ITA No. 7477/Del/2017 (Revenue’s cross appeal) 3. This assessee’s appeal ITA No. 7344/Del/2017

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

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

143(3)/144C Oil Tools ME A.Y. 2015-16 Appeal No. 93/CIT(A)- (3)(b) Ltd. 2 /2017-18/Noida Dated 22.06.2018 2. Heard both the parties at length. Case file perused. We proceed assessment year wise for the sake of convenience and brevity. A.Y. 2013-14 ITA No. 7477/Del/2017 (Revenue’s cross appeal) 3. This assessee’s appeal ITA No. 7344/Del/2017

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

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

143(3)/144C Oil Tools ME A.Y. 2015-16 Appeal No. 93/CIT(A)- (3)(b) Ltd. 2 /2017-18/Noida Dated 22.06.2018 2. Heard both the parties at length. Case file perused. We proceed assessment year wise for the sake of convenience and brevity. A.Y. 2013-14 ITA No. 7477/Del/2017 (Revenue’s cross appeal) 3. This assessee’s appeal ITA No. 7344/Del/2017

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

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

143(3)/144C Oil Tools ME A.Y. 2015-16 Appeal No. 93/CIT(A)- (3)(b) Ltd. 2 /2017-18/Noida Dated 22.06.2018 2. Heard both the parties at length. Case file perused. We proceed assessment year wise for the sake of convenience and brevity. A.Y. 2013-14 ITA No. 7477/Del/2017 (Revenue’s cross appeal) 3. This assessee’s appeal ITA No. 7344/Del/2017