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

d. The learned CIT(A) erred in not rejecting the action of the learned AO to reject the PAR submitted by the Appellant based on the following allegations: • Comparable companies identified in the PAR are of different business dynamics and economies, none of the comparable companies are engaged in services of the nature performed by the Appellant, the comparables

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

d. The learned CIT(A) erred in not rejecting the action of the learned AO to reject the PAR submitted by the Appellant based on the following allegations: • Comparable companies identified in the PAR are of different business dynamics and economies, none of the comparable companies are engaged in services of the nature performed by the Appellant, the comparables

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

d. The learned CIT(A) erred in not rejecting the action of the learned AO to reject the PAR submitted by the Appellant based on the following allegations: • Comparable companies identified in the PAR are of different business dynamics and economies, none of the comparable companies are engaged in services of the nature performed by the Appellant, the comparables

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

d. The learned CIT(A) erred in not rejecting the action of the learned AO to reject the PAR submitted by the Appellant based on the following allegations: • Comparable companies identified in the PAR are of different business dynamics and economies, none of the comparable companies are engaged in services of the nature performed by the Appellant, the comparables

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

d. The learned CIT(A) erred in not rejecting the action of the learned AO to reject the PAR submitted by the Appellant based on the following allegations: • Comparable companies identified in the PAR are of different business dynamics and economies, none of the comparable companies are engaged in services of the nature performed by the Appellant, the comparables

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

d. The learned CIT(A) erred in not rejecting the action of the learned AO to reject the PAR submitted by the Appellant based on the following allegations: • Comparable companies identified in the PAR are of different business dynamics and economies, none of the comparable companies are engaged in services of the nature performed by the Appellant, the comparables

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

d. The learned CIT(A) erred in not rejecting the action of the learned AO to reject the PAR submitted by the Appellant based on the following allegations: • Comparable companies identified in the PAR are of different business dynamics and economies, none of the comparable companies are engaged in services of the nature performed by the Appellant, the comparables

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

17:46, 20/05/2025] RAJESH KUMAR: total turnover of Rs. 16,61,28,493/-. During the year a total amount of Rs.34,74,000/-in cash has been deposited by assessee in old SBNs of Rs.1000/- and Rs.500/-. 6.2. The assessee during the course of assessment proceeding explained that the deposits were his cash sales in old currency SBNS and were

ACHARYA BALKRISHNA,HARIDWAR vs. DCIT, DEHRADUN

In the result appeal of the assessee is allowed

Bench: SHRI YOGESH KUMAR U.S. (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

68 as unexplained cash credits and Rs. 1,25,000/- as unexplained expenditure u/s 69C for obtaining such loan were made in the hands of the assessee. Against the said order an appeal was filed before the Ld. CIT(A) who dismissed the appeal of the assessee. 3. Aggrieved by the said order, assessee is in appeal before the Tribunal

BG EXPLORATION & PRODUCTION INDIA LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, DDIT/ADIT (INTERNATIONAL TAXATION), CIRCLE -1, DEHRADUN

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

d Further the TPO asked that assessee to submit details of services rendered by the AE, the allocation key of allocation of the expenses by the AE and 3 evidence that the services were requisitioned by the assessee from the AE. Necessary details were not furnished by the assessee. The assessee claimed that the services were received

JOINT COMMISSIONER OF INCOME TAX, SUBHASH ROAD DEHADUN vs. M/S TIMES SQUARE, SAHASTRADHARA ROAD

In the result, appeal of the Revenue is dismissed

D'.\n\nWHY CASH WITHDRAWAN WAS DEPOSITED BACK IN FY 2016-17:\n\nWhen demonetization was announced on 08-11-2016, the assessee was given a small window of 2\nmonths (from 09-11-2016 to 30-12-2016) to deposit back the cash. The assessee very quickly\ndeposited back the cash on 2 dates immediately

JCIT(OSD), CIRCLE 111, DEHRADUN, SUBHASH ROAD vs. M/S SURYANCHAL FURNITECH, BAHADRABAD INDUSTRIAL AREA, HARIDWAR

Appeal is partly allowed

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 82/Ddn/2025 : Asstt. Year: 2017-18 Jcit(Osd), Vs M/S Suryanchal Furnitech, Circle-111, F-104, Bahadrabad Industrial Dehradun-248001 Area, Haridwar-249402 (Appellant) (Respondent) Pan No. Abofs3475L Assessee By : Sh. Himanshu Sharma, Adv. Revenue By : Sh. A. S. Rana, Sr. Dr Date Of Hearing: 15.01.2026 Date Of Pronouncement: 21.01.2026 Order Per Satbeer Singh Godara: This Revenue’S Appeal For Assessment Year 2017-18, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1074074259(1) Dated 05.03.2025, In Proceedings U/S 143(3) Of The Income Tax Act, 1961. 2. Heard Both The Parties At Length. Case File Perused.

17 was to the tune of Rs. 3,66,93,397/ amount claimed to be received in cash of Rs. 82,91,500 amount claimed to be received in cash of Rs. 82,91,500 amount claimed to be received in cash of Rs. 82,91,500 and balance receivable as Rs.2,84,01,897). Although the lance receivable

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

17,33,89,023/-) and completed the assessment. The ld. AO further observed that the following receipts were not considered as part of gross contractual receipts by the assessee :- a) Service tax receipts amounting to Rs 241,32,45,767/- b) Lost in Hole amounting to Rs 80,68,19,422/- c) Reimbursement amounting

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

17,33,89,023/-) and completed the assessment. The ld. AO further observed that the following receipts were not considered as part of gross contractual receipts by the assessee :- a) Service tax receipts amounting to Rs 241,32,45,767/- b) Lost in Hole amounting to Rs 80,68,19,422/- c) Reimbursement amounting

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

17,33,89,023/-) and completed the assessment. The ld. AO further observed that the following receipts were not considered as part of gross contractual receipts by the assessee :- a) Service tax receipts amounting to Rs 241,32,45,767/- b) Lost in Hole amounting to Rs 80,68,19,422/- c) Reimbursement amounting

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

17,33,89,023/-) and completed the assessment. The ld. AO further observed that the following receipts were not considered as part of gross contractual receipts by the assessee :- a) Service tax receipts amounting to Rs 241,32,45,767/- b) Lost in Hole amounting to Rs 80,68,19,422/- c) Reimbursement amounting

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)

D E R PER AMIT SHUKLA, JM The aforesaid appeal has been filed by the assessee against impugned order dated 22.6.2018 passed by Ld. CIT(A) -2 Noida for the quantum of assessment passed u/s 143(3) / 144C(3)(b) for the assessment year 2015-16. In the grounds of appeal assessee has raised following grounds:- “1.On the facts

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

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

d ACIT CIT(A)-2, Noida, 143(3)/144C A.Y. 2015-16 Oil Tools ME Appeal No. 93/CIT(A)- (3)(b) Ltd. 2/2017-18/ Noida Dated 22.06.2018 4. 7477/Del/2017 ACIT Weatherford CIT(A)-2, Noida, 143(3)/144C Oil Tools ME A.Y. 2013-14 Appeal No. 45/CIT(A)- (3)(b) Ltd. 2 /2016-17 Dated 27.09.2017 5. 417/Del/2018 ACIT Weatherford