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

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

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

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

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

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

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

In the result, assessee's appeals; ITA No

ii) Allied Infra & Others Group were\nsearched under section 132 of the Income Tax Act, 1961 (‘Act'). Allied Infra &\nOthers Group consists of Smt. Priya Sharma, Shri Sudhir Chawla, Shri\nChaudhary and Others. The assessee belongs to Allied Infra & Others Group.\nSearch assessments of six AYs were initiated in the case of the assessee under\nsection 153A

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

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

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

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

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 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