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

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

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 40A(3

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

3 SCL 422. FAILURE TO ADHERE TO THE MANDATORY PROCEDURE PRESCRIBED UNDER SECTION 144C OF THE ACT WOULD VITIATE THE ENTIRE PROCEEDINGS AND THE SAME CANNOT BE TREATED AS AN IRREGULARITY/CURABLE DEFECT. 22. The appellant has also contended that the failure to follow the procedure under section 144C of the Act, at the highest, was a procedural irregularity

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

In the result, assessee's appeals; ITA No

sections": [ "143(3)", "153A", "142(2A)", "68", "69", "132", "147", "148" ], "issues": "Whether assessment under Section 153A for unabated

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

section 143(3) of the Act. The assessment was reopened u/s 147 of the Income Tax Act, 1961 and notice u/s 148 was issued on 3 G & T Resources (Europe) Ltd. 28.03.2011. In response to the notice, the assessee vide its letter dated 05.08.2011 submitted with enclosing the copy o the return that was filed

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

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

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

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

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

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), DEHRADUN, DEHRADUN vs. CHAKRATA FIRST AND ASSOCIATES, JAIPUR

Appeal is dismissed

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh(Through Video Conferencing) Assessment Year: 2017-18 Acit, Vs. Chakrata First & Circle-1(1)(1), Associates, C/O- Amit Tak 41 Dehradun Sanjay Marg, Hathori Fort, Jaipur, Rajasthan Pan: Aalfc2896B (Appellant) (Respondent) Assessee By Sh. S.K. Ahuja, Ar Department By Sh. Amar Pal Singh, Sr. Dr

143(3) has been perused. The details as submitted have been examined. The grounds of appeal 1 to 4 are taken together as it is effectively directed against addition of Rs.34,74,000/- u/s 69A which has been considered by the AO as not allowable cash deposits as it were deposits made in SBNs. 7.2. Findings on Ground of appeal

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)

143(3) of the Income Tax Act, 1961 without jurisdiction. 2. The case of the appellant does not fall under any of the categories for compulsory scrutiny as per criteria of selection of cases for compulsory scrutiny. 3. There was no search warrant in the name of appellant. There was no incriminating material seized during the search operation from hands

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)

143(3) of the Income Tax Act, 1961 without jurisdiction. 2. The case of the appellant does not fall under any of the categories for compulsory scrutiny as per criteria of selection of cases for compulsory scrutiny. 3. There was no search warrant in the name of appellant. There was no incriminating material seized during the search operation from hands