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

iv. Revenue received from PSC partners of ₹ 748,383,154/– on account of supply of imported material to be included in the revenue chargeable to tax u/s 44 BB of the income tax act as proposed to the claim of the assessee that these are not chargeable to tax in India. v. Revenue received from non-PSC partners amounting

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

iv. Revenue received from PSC partners of ₹ 748,383,154/– on account of supply of imported material to be included in the revenue chargeable to tax u/s 44 BB of the income tax act as proposed to the claim of the assessee that these are not chargeable to tax in India. v. Revenue received from non-PSC partners amounting

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

iv. Revenue received from PSC partners of ₹ 748,383,154/– on account of supply of imported material to be included in the revenue chargeable to tax u/s 44 BB of the income tax act as proposed to the claim of the assessee that these are not chargeable to tax in India. v. Revenue received from non-PSC partners amounting

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

iv. Revenue received from PSC partners of ₹ 748,383,154/– on account of supply of imported material to be included in the revenue chargeable to tax u/s 44 BB of the income tax act as proposed to the claim of the assessee that these are not chargeable to tax in India. v. Revenue received from non-PSC partners amounting

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

iv. Revenue received from PSC partners of ₹ 748,383,154/– on account of supply of imported material to be included in the revenue chargeable to tax u/s 44 BB of the income tax act as proposed to the claim of the assessee that these are not chargeable to tax in India. v. Revenue received from non-PSC partners amounting

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

iv. Revenue received from PSC partners of ₹ 748,383,154/– on account of supply of imported material to be included in the revenue chargeable to tax u/s 44 BB of the income tax act as proposed to the claim of the assessee that these are not chargeable to tax in India. v. Revenue received from non-PSC partners amounting

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

section 145(3) of the Act and applied net profit @ 8% of the annual sale of Rs.1,44,77,740/- as under: “4.12 As per return of income filed by the assessee, a turnover of Rs.1,44,77,740/- has been shown. After claiming various expenses, a net profit of Rs.2,86,150/- has been shown against the turnover

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

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 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

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 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- 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

iv) Disallowance of interest under section 14A. (v) Taxability of contract receipt of Rs.8,19,265/- on accrual basis 4. The facts of the case giving rise to these appeals are that the assessee, a Government Corporation, filed its Income Tax Returns (hereinafter, the ‘ITR’) of AYs 2012-13 and 2013-14 declaring tentative losses of (-) Rs.76

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

iv) Disallowance of interest under section 14A. (v) Taxability of contract receipt of Rs.8,19,265/- on accrual basis 4. The facts of the case giving rise to these appeals are that the assessee, a Government Corporation, filed its Income Tax Returns (hereinafter, the ‘ITR’) of AYs 2012-13 and 2013-14 declaring tentative losses of (-) Rs.76

AMRIT VARSHA UDYOG LTD,KOTDWAR vs. DCIT CIRCLE 1, DEHRADUN

In the result, the Appeal of the Assessee is dismissed

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

2 AmritVarshaUdyog Ltd. addition of Rs. 30,76,798/- u/s. 69C of the IT Act. Against the same the assessee has preferred this appeal which was rejected by the CIT(A) vide order dated 30.09.2022. 5.2 Further the AO has re-opened the assessment u/s. 147 of the IT Act on the issue of bogus purchases made to the extent

RAJU VERMA,DEHRADUN vs. DCIT, DEHRADUN

In the result, the appeal of the assessee is allowed

Bench: SHRI ANUBHAV SHARMA (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

IV, Kanpur, (‘the Ld. CIT(A)’ for short) dated 17.02.2027, for Assessment Year 2012-13. 2. During the course of hearing vide letter dt. 13.11.2024, assessee filed an application under Rule 11 of the Income Tax (Appellate Tribunal) Rules, 1963 (ITAT Rules, in short) and raised one additional ground which reads as under: “That having regard to the facts