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 in respect of unsecured loans have not been obtained during the Financial Year relevant to the Assessment Year 2011-12. The appellant therefore, pray that the appeal may be 4. admitted and orders may be passed rendering justice to the appellant. That the Appellant craves for the right to add, alter, amend 5. or delete any ground of appeal

DCIT, RISHIKESH vs. M/S UTTRANCHAL IRON & ISPAT LTD.,, KOTDWAR

In the result, this appeal of the assessee (ITA No

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

28,810/- made on account of net profit estimated by the AO by invoking the provisions of section 145 of the Income Tax Act, 1961 as discrepancies found in the books and the book results shown by the assessee was not amenable to verification. 2. The Ld. CIT (A) has erred in law and on facts in deleting addition

UTTRANCHAL IRON & ISPAT LTD.,KOTDWAR vs. DCIT, CIRCLE- 1(4)(1), RISHIKESH

In the result, this appeal of the assessee (ITA No

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

28,810/- made on account of net profit estimated by the AO by invoking the provisions of section 145 of the Income Tax Act, 1961 as discrepancies found in the books and the book results shown by the assessee was not amenable to verification. 2. The Ld. CIT (A) has erred in law and on facts in deleting addition

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

28,05,028/- on account of inventory written off and also made certain addition/disallowances on account of depreciation. The assessee approached the DRP. The DRP, following its order for the preceding assessment years, upheld the addition made by the TPO by observing as under:- 2 “2.1 Grounds 1 to 7 relate to the transfer pricing adjustment proposed for the international

M/S PARASNATH FUELS (P) LTD.,DEHRADUN vs. DCIT, DEHRADUN

In the result, appeal of the assessee stands partly allowed for statistical purposes

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalparasnath Fuels Pvt. Ltd., The Dcit, Circle 1(1), 28 Feet Road, Dehradun Vikas Nagar, Vs Dehradun - 248198 Pan-Aaicp2190D Assessee Revenue Assessee By Dr. Rakesh Gupta, Adv., Shri Somil Agarwal, Adv. Revenue By Sh. Amar Pal Singh, Jcit Sr. Dr Date Of Hearing 11.09.2025 Date Of Pronouncement 28.11.2025 Order Per Manish Agarwal, Am, This Appeal Is Filed By The Assessee Against The Order Of The National Faceless Appellate Centre [Cit(A), In Short], Dated 08.10.2024 In Appeal No. Nfac/2016-17/10104734 Arising Out Of The Order Passed U/S 147 Of The Income Tax Act, 1961 (‘The Act’) Dt. 08.10.2024 For Assessment Year 2017-18. 2. The Assessee Has Raised Following Grounds Of Appeal: 1. That Having Regard To The Facts & Circumstances Of The Case, Assumption Of Jurisdiction In Initiating The Proceedings U/S 147 & Passing The Impugned Order U/S 147/144B & That Too Without Complying With Mandatory Conditions U/S 147 To 151A Parasnath Fuels Pvt.Ltd. Vs. Dcit

68 of the Act and further invoked the provisions of section 115BBE of the Act. As per ld. AR before ld. CIT(A), assessee sought time to file the relevant details however, the ld. CIT(A) has passed the order without providing sufficient opportunity to the assessee. Before us,vide letter dt. 08.09.2025, the ld. AR filed a prayer

PUSHPA DEVI,RISHIKESH vs. INCOME TAX OFFICER, RISHIKESH

In the result the Appeal of the Assessee is allowed

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Pushpa Devi Vs. Income Tax Officer, 31-Awas Vikas Colony, Ward 1(4) (1), Verbhadara Road, Rishikesh, Rishikesh, 249201, Uttarakhand Rishikesh, Uttarakhand Pan: Aldpd9616P Appellant Respondent Assessee By Sh. K. K. Juneja, Adv Revenue By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 10/07/2025 Date Of Pronouncement 08/08/2025 Order

Section 144B of the Income Tax Act, 1961 ('Act' for short) by making an addition of Rs. 36,05,530/- on account of suppression of sale receipts u/s 28 of the Act and also made addition of Rs. 13,74,000/- u/s 68

ACIT, UTTRAKHAND vs. M/S. UTTARANCHAL JAL VIDYUT NIGAM LTD., DEHRADUN

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri R.K. Panda & Shri Challa Nagendra Prasadassessment Year: 2012-13 Acit, Vs. Uttaranchal Jal Vidyut Circle-2, Nigam Ltd., 13-A, Subhash Road, Ujjwal, Maharani Bagh, Uttarakhand. Gms Road, Dehradun. Pan: Aaacu6672R (Appellant) (Respondent) Assessee By : Dr. Rakesh Gupta, Advocate & Shri Somil Aggarwal, Advocate Revenue By : Smt. Poonam Sharma, Sr. Dr Date Of Hearing : 22.12.2021 Date Of Pronouncement : 24.12.2021 Order Per R.K. Panda, Am: This Appeal Filed By The Revenue Is Directed Against The Order Dated 29Th December, 2016 Of The Cit(A), Dehradun, Relating To Assessment Year 2012-13. 2. The Only Effective Ground Raised By The Revenue Reads As Under:- “1. The Ld.Cit(A) Has Erred In Law & On Facts By Allowing Depreciation On Assets For Which The Actual Cost As Per Section 43(1) Of The Income Tax Act, 1961 Was Nil. 2. The Order Of The Ld.Cit(Appeals) Be Set Aside & That Of The Assessing Officer Be Restored.”

68,564/- 14 being depreciation on assets acquired from UJVNL and Rs.45,31,58,363/- on account of capacity charges, deemed generation charges and capacity index incentive. We find, the ld.CIT(A) deleted both the additions, the reasons of which have already been reproduced in the preceding paragraphs. We find, both the issues stand decided by the Tribunal in assessee

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 of the assessee is partly allowed

Bench: Shri R.K. Panda & Shri V.P. Raoassessment Years: 2016-17

28,48,22,523 in total towards international transactions pertaining to payment of management service and unit charges, IM charges and payroll expenses to its AE. Ground No. 2: Erroneous rejection of Transactional Net Margin Method ("TNMM”) and selection of Comparable Uncontrolled Price ("CUP”) Method 2.1. The learned TPO / AO / DRP / have erred in law and on facts by disregarding

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

28. The learned authorised representative submitted that the issue is squarely covered in favour of the assessee by the decision of the full bench of the jurisdictional High Court in 334 ITR 79. He also relied on several other judicial precedents. We have carefully considered the rival contention and perused the orders of the 29. lower authorities. In fact

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

28. The learned authorised representative submitted that the issue is squarely covered in favour of the assessee by the decision of the full bench of the jurisdictional High Court in 334 ITR 79. He also relied on several other judicial precedents. We have carefully considered the rival contention and perused the orders of the 29. lower authorities. In fact

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

28. The learned authorised representative submitted that the issue is squarely covered in favour of the assessee by the decision of the full bench of the jurisdictional High Court in 334 ITR 79. He also relied on several other judicial precedents. We have carefully considered the rival contention and perused the orders of the 29. lower authorities. In fact

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

28. The learned authorised representative submitted that the issue is squarely covered in favour of the assessee by the decision of the full bench of the jurisdictional High Court in 334 ITR 79. He also relied on several other judicial precedents. We have carefully considered the rival contention and perused the orders of the 29. lower authorities. In fact

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

28. The learned authorised representative submitted that the issue is squarely covered in favour of the assessee by the decision of the full bench of the jurisdictional High Court in 334 ITR 79. He also relied on several other judicial precedents. We have carefully considered the rival contention and perused the orders of the 29. lower authorities. In fact

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

28. The learned authorised representative submitted that the issue is squarely covered in favour of the assessee by the decision of the full bench of the jurisdictional High Court in 334 ITR 79. He also relied on several other judicial precedents. We have carefully considered the rival contention and perused the orders of the 29. lower authorities. In fact

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

28. The learned authorised representative submitted that the issue is squarely covered in favour of the assessee by the decision of the full bench of the jurisdictional High Court in 334 ITR 79. He also relied on several other judicial precedents. We have carefully considered the rival contention and perused the orders of the 29. lower authorities. In fact

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

68,19,422/- c) Reimbursement amounting to Rs 10,84,47,712/-. 4.5. The ld. AO held that the service tax receipts mentioned in a) above should be included as part of gross contractual receipts taxable u/s 44BB of the Act. As far as amount received towards Lost in Hole, the ld. AO by following the decision

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

68,19,422/- c) Reimbursement amounting to Rs 10,84,47,712/-. 4.5. The ld. AO held that the service tax receipts mentioned in a) above should be included as part of gross contractual receipts taxable u/s 44BB of the Act. As far as amount received towards Lost in Hole, the ld. AO by following the decision

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

68,19,422/- c) Reimbursement amounting to Rs 10,84,47,712/-. 4.5. The ld. AO held that the service tax receipts mentioned in a) above should be included as part of gross contractual receipts taxable u/s 44BB of the Act. As far as amount received towards Lost in Hole, the ld. AO by following the decision