RAJESH AGGARWAL ,DEHRADUN vs. THE DEPUTY COMMISSIONER OF INCOME TAX OFFICER, CENTRAL CIRCLE, DEHRADUN

In the result, all the appeals of the assessee are allowed

68 of the Act and consequential disallowance of interest on such loans. Hence, the earlier assessment years for assessment years 2011-12 to 2015-16 cannot be disturbed at all by learned AO while framing the search assessments under section 153A of the Act. This issue is no longer res integra in view of the recent decision

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

section 69A of the Act. The Hon'ble Supreme Court in the case of CIT vs Devi Prasad Vishwnath Prasad (1969) 72ITR194 (SC) held that "It is for the assessee to prove that even if the cash credit represents income, it is income from a source, which has already been taxed". The appellant has already offered the sales

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

In the result, appeal of the Revenue is dismissed

24,34,000/- u/s 69A of the Act as the nature and source of the\nsaid money is proved to be out of books of accounts and is explained. Thus, the\ngrounds raised towards addition made u/s 69A by the appellant stands allowed on\nlaw as well as on facts and consequently the the rates of taxation levied

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

24,405/- towards the bogus purchases.” 3. Aggrieved by the assessment order, Assessee preferred an Appeal before the ld. CIT(A). The ld. CIT(A) vide order dated 18.11.2024, confirmed the addition made on account of purchase from M/s Delhi Steel Trading Co. and M/s New India Traders of Rs.15,10,506/- and Rs.53,00,074/-, respectively. Aggrieved

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

68 taxmann.com 377/241 Taxman 3.8/388 ITR 383 (Delhi) this Court, after discussing the judgments of the Andhra Pradesh High Court, High Court of Bombay as well as Madras High Court in Vijay Televisions (P.) Ltd. v. DRP [20141 I.T.A.No.6114/Del/2017 & CO No. 13/Del/2018 46 taxmann.com 100/225 Taxman 35/369 ITR 113 has held that failure to pass a draft assessment

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)

section 44BB of the Act: • Corpro Systems Limited, UK, In re [(2016) 389 ITR 0029]; • Addl. DIT (International Taxation) vs Halliburtan Offshore Services Inc. [(2016) 47 CCH 0425] (Delhi ITAT); • ITO (International Taxation) vs. ONGC [(2016) ITA No. 1596, 1597, 1598 & 1599/Del/2012] (Delhi ITAT); • National Oil Well Maintenance Company vs DCIT [(2018) (89 taxmann.com 24)]; • Production Testing Services

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

section 44BB of the Act:  Corpro Systems Limited, UK, In re [(2016) 389 ITR 0029];  Addl. DIT (International Taxation) vs Halliburtan Offshore Services Inc. [(2016) 47 CCH 0425] (Delhi ITAT);  ITO (International Taxation) vs. ONGC [(2016) ITA No. 1596, 1597, 1598 & 1599/Del/2012] (Delhi ITAT);  National Oil Well Maintenance Company vs DCIT [(2018) (89 taxmann.com 24)];  Production Testing Services

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

section 44BB of the Act:  Corpro Systems Limited, UK, In re [(2016) 389 ITR 0029];  Addl. DIT (International Taxation) vs Halliburtan Offshore Services Inc. [(2016) 47 CCH 0425] (Delhi ITAT);  ITO (International Taxation) vs. ONGC [(2016) ITA No. 1596, 1597, 1598 & 1599/Del/2012] (Delhi ITAT);  National Oil Well Maintenance Company vs DCIT [(2018) (89 taxmann.com 24)];  Production Testing Services

METRO FROZEN FRUIT & VEGETABLES PVT. LTD.,ROORKEE vs. DCIT, CIRCLE, HARIDWAR

In the result, the appeal of the assessee is party allowed

Bench: Shri R.K. Panda & Shri N. K. Choudhry[Assessment Year: 2009-10] Metro Frozen Fruits & Dcit, Vegetables Pvt. Ltd. Circle Haridwar, Plot No.22, Rajpur, Vs Uttarakhan Bhagwanpur, Roorkee, Uttrakhand Pan-Aaecm4521F Assessee Revenue Assessee By Sh. Piyush Kuchhal, Fca Revenue By Ms. Poonam Sharma Cit-Dr Date Of Hearing 23.02.2022 Date Of Pronouncement 08.03.2022 Order Per R.K. Panda, Am, This Appeal Filed By The Assessee Is Directed Against The Order Dated 24.01.2019 Of The Learned Cit(A), Dehradun, Relating To Assessment Year 2009-10. 2. The Grounds Raised By The Assessee Are As Under:-

Section 143(3) of the Act. 6. On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law rejecting the contention of the assessee that approval having been granted in a mechanical manner is bad in law, hence the consequential proceedings u/s 147 of the Act are illegal and liable

INSTITUTE OF CLINICAL RESEARCH (INDIA) SOCIETY,DEHRADUN vs. ACIT, DEHRADUN

In the result, the appeal filed by the assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

section 36(1)(iii) of the Act. 15. When the aggrieved assessee went in appeal before the ld. CIT(A), the ld. CIT(A) deleted the addition following the CIT(A) decision of A.Y 2006-07. 16. Now the aggrieved Revenue is in appeal before us. 15. The ld DR vehemently argued that the assessee has diverted its interest

DCIT, DEHRADUN vs. M/S INSTITUTE OF CLINICAL RESEARCH (INDIA) SOCIETY,, DEHRADUN

In the result, the appeal filed by the assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

section 36(1)(iii) of the Act. 15. When the aggrieved assessee went in appeal before the ld. CIT(A), the ld. CIT(A) deleted the addition following the CIT(A) decision of A.Y 2006-07. 16. Now the aggrieved Revenue is in appeal before us. 15. The ld DR vehemently argued that the assessee has diverted its interest

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

24,455,503/- to the gross receipts without appreciating that the said amount represented reimbursement of service tax which is not chargeable to tax. Addition qua service tax receipts from non-PSC partners 8. The Ld AO has erred on facts and in law in adding a sum of Rs. 8,014,145/- to the gross receipts chargeable

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

24,455,503/- to the gross receipts without appreciating that the said amount represented reimbursement of service tax which is not chargeable to tax. Addition qua service tax receipts from non-PSC partners 8. The Ld AO has erred on facts and in law in adding a sum of Rs. 8,014,145/- to the gross receipts chargeable

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

24,455,503/- to the gross receipts without appreciating that the said amount represented reimbursement of service tax which is not chargeable to tax. Addition qua service tax receipts from non-PSC partners 8. The Ld AO has erred on facts and in law in adding a sum of Rs. 8,014,145/- to the gross receipts chargeable

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

24,455,503/- to the gross receipts without appreciating that the said amount represented reimbursement of service tax which is not chargeable to tax. Addition qua service tax receipts from non-PSC partners 8. The Ld AO has erred on facts and in law in adding a sum of Rs. 8,014,145/- to the gross receipts chargeable

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

24,455,503/- to the gross receipts without appreciating that the said amount represented reimbursement of service tax which is not chargeable to tax. Addition qua service tax receipts from non-PSC partners 8. The Ld AO has erred on facts and in law in adding a sum of Rs. 8,014,145/- to the gross receipts chargeable

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

24,455,503/- to the gross receipts without appreciating that the said amount represented reimbursement of service tax which is not chargeable to tax. Addition qua service tax receipts from non-PSC partners 8. The Ld AO has erred on facts and in law in adding a sum of Rs. 8,014,145/- to the gross receipts chargeable

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

24,455,503/- to the gross receipts without appreciating that the said amount represented reimbursement of service tax which is not chargeable to tax. Addition qua service tax receipts from non-PSC partners 8. The Ld AO has erred on facts and in law in adding a sum of Rs. 8,014,145/- to the gross receipts chargeable