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48 results for “section 68”+ Section 3(1)(b)clear

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Key Topics

Section 153A41Section 153D40Addition to Income40Section 44B34Section 153C31Section 143(3)22Section 915Section 14813Section 6811Limitation/Time-bar

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

ITA 199/DDN/2019[2013-14]Status: DisposedITAT Dehradun23 Jun 2023AY 2013-14
Section 115BSection 132Section 132(4)Section 139(1)Section 153ASection 68

1) r.w.s. 143(3) are bad in law since the same income has been taxed twice, once in Assessment year 2017-18 and again in the assessment year 2011-12 to 2016-17. 18. Since, the aforesaid additional grounds go to the root of the matter challenging the validity of assessments for the assessment years

MI OVERSEAS LTD.,NEW DELHI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

Showing 1–20 of 48 · Page 1 of 3

7
Transfer Pricing7
Comparables/TP7
ITA 3072/DEL/2012[2009-10]Status: DisposedITAT Dehradun08 Jun 2021AY 2009-10

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

3. The learned CIT(A) has erred in rejecting the Appellant‟s claim, wherein the Appellant had offered 2% of the revenues from offshore supply of imported materials from PSC and Non-PSC partners to tax following the assessment order for AY 2006-07, in order to avoid litigation and to buy peace of mind. 4. The learned

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

ITA 5564/DEL/2013[2007-08]Status: DisposedITAT Dehradun08 Jun 2021AY 2007-08

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

3. The learned CIT(A) has erred in rejecting the Appellant‟s claim, wherein the Appellant had offered 2% of the revenues from offshore supply of imported materials from PSC and Non-PSC partners to tax following the assessment order for AY 2006-07, in order to avoid litigation and to buy peace of mind. 4. The learned

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 5584/DEL/2013[2010-11]Status: DisposedITAT Dehradun08 Jun 2021AY 2010-11

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

3. The learned CIT(A) has erred in rejecting the Appellant‟s claim, wherein the Appellant had offered 2% of the revenues from offshore supply of imported materials from PSC and Non-PSC partners to tax following the assessment order for AY 2006-07, in order to avoid litigation and to buy peace of mind. 4. The learned

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 2956/DEL/2013[2006-07]Status: DisposedITAT Dehradun08 Jun 2021AY 2006-07

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

3. The learned CIT(A) has erred in rejecting the Appellant‟s claim, wherein the Appellant had offered 2% of the revenues from offshore supply of imported materials from PSC and Non-PSC partners to tax following the assessment order for AY 2006-07, in order to avoid litigation and to buy peace of mind. 4. The learned

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 5583/DEL/2013[2007-08]Status: DisposedITAT Dehradun08 Jun 2021AY 2007-08

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

3. The learned CIT(A) has erred in rejecting the Appellant‟s claim, wherein the Appellant had offered 2% of the revenues from offshore supply of imported materials from PSC and Non-PSC partners to tax following the assessment order for AY 2006-07, in order to avoid litigation and to buy peace of mind. 4. The learned

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

ITA 3045/DEL/2013[2006-07]Status: DisposedITAT Dehradun08 Jun 2021AY 2006-07

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

3. The learned CIT(A) has erred in rejecting the Appellant‟s claim, wherein the Appellant had offered 2% of the revenues from offshore supply of imported materials from PSC and Non-PSC partners to tax following the assessment order for AY 2006-07, in order to avoid litigation and to buy peace of mind. 4. The learned

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

ITA 5565/DEL/2013[2010-11]Status: DisposedITAT Dehradun08 Jun 2021AY 2010-11

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

3. The learned CIT(A) has erred in rejecting the Appellant‟s claim, wherein the Appellant had offered 2% of the revenues from offshore supply of imported materials from PSC and Non-PSC partners to tax following the assessment order for AY 2006-07, in order to avoid litigation and to buy peace of mind. 4. The learned

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

ITA 5305/DEL/2018[2015-16]Status: DisposedITAT Dehradun15 Sept 2023AY 2015-16

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

For Appellant: Shri P. J. Pardiwalla, Sr. AdvFor Respondent: Shri Mayank Kumar, JCIT, DR
Section 143(3)Section 44BSection 9(1)(vii)

3. Both the parties mutually pleaded that the appeals for Asst Year 2015-16 to be taken as the lead year and the decision rendered thereon would apply with equal force for Asst Year 2014-15 also, except with variance in figures. 4. The Ground Nos. 1 to 4 raised by the assessee and Ground Nos. 1 to 7 raised

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

ITA 5223/DEL/2018[2015-16]Status: DisposedITAT Dehradun15 Sept 2023AY 2015-16

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

For Appellant: Shri P. J. Pardiwalla, Sr. AdvFor Respondent: Shri Mayank Kumar, JCIT, DR
Section 143(3)Section 44BSection 9(1)(vii)

3. Both the parties mutually pleaded that the appeals for Asst Year 2015-16 to be taken as the lead year and the decision rendered thereon would apply with equal force for Asst Year 2014-15 also, except with variance in figures. 4. The Ground Nos. 1 to 4 raised by the assessee and Ground Nos. 1 to 7 raised

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

ITA 6173/DEL/2017[2014-15]Status: DisposedITAT Dehradun15 Sept 2023AY 2014-15

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

For Appellant: Shri P. J. Pardiwalla, Sr. AdvFor Respondent: Shri Mayank Kumar, JCIT, DR
Section 143(3)Section 44BSection 9(1)(vii)

3. Both the parties mutually pleaded that the appeals for Asst Year 2015-16 to be taken as the lead year and the decision rendered thereon would apply with equal force for Asst Year 2014-15 also, except with variance in figures. 4. The Ground Nos. 1 to 4 raised by the assessee and Ground Nos. 1 to 7 raised

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

ITA 6126/DEL/2017[2013-14]Status: DisposedITAT Dehradun15 Sept 2023AY 2013-14

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

For Appellant: Shri P. J. Pardiwalla, Sr. AdvFor Respondent: Shri Mayank Kumar, JCIT, DR
Section 143(3)Section 44BSection 9(1)(vii)

3. Both the parties mutually pleaded that the appeals for Asst Year 2015-16 to be taken as the lead year and the decision rendered thereon would apply with equal force for Asst Year 2014-15 also, except with variance in figures. 4. The Ground Nos. 1 to 4 raised by the assessee and Ground Nos. 1 to 7 raised

DCIT, DEHRADUN vs. SHRI RAMESH BATTA, DEHRADUN

In the result, appeal of the Assessee in both the cases are allowed and appeal filed by the Revenue in both the cases are dismissed

ITA 3137/DEL/2017[2008-09]Status: DisposedITAT Dehradun21 Feb 2025AY 2008-09

Bench: Shri Anubhav Sharma & Shri Manish Agarwalacit, Shri Ramesh Batta Central Circle, 81/210, Kaulagarh Road, Vs. Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Shri Ramesh Batta Dy. Cit, 81/210, Kaulagarh Central Circle, Vs. Road, Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Acit, Shri Ramesh Batta, Central Circle, As Agent Of Smt. Kavita Vs. Dehradun. Ahuja, 81/210, Kaulagarh Road, Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent)

Section 143(2)Section 153ASection 153D

b) of sub-section (1) of Section 153A of the Act. It is beneficial to refer to the decision of the High Court of Judicature at Allahabad in the case of PCIT v. Sapna Gupta [2022 SCC OnLine All 1294] which captures with precision the scope of the concerned provision and more significantly, the import of the phrase

SHRI RAMESH BATTA,DEHRADUN vs. ACIT, DEHRADUN

In the result, appeal of the Assessee in both the cases are allowed and appeal filed by the Revenue in both the cases are dismissed

ITA 4901/DEL/2016[2008-09]Status: DisposedITAT Dehradun21 Feb 2025AY 2008-09

Bench: Shri Anubhav Sharma & Shri Manish Agarwalacit, Shri Ramesh Batta Central Circle, 81/210, Kaulagarh Road, Vs. Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Shri Ramesh Batta Dy. Cit, 81/210, Kaulagarh Central Circle, Vs. Road, Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Acit, Shri Ramesh Batta, Central Circle, As Agent Of Smt. Kavita Vs. Dehradun. Ahuja, 81/210, Kaulagarh Road, Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent)

Section 143(2)Section 153ASection 153D

b) of sub-section (1) of Section 153A of the Act. It is beneficial to refer to the decision of the High Court of Judicature at Allahabad in the case of PCIT v. Sapna Gupta [2022 SCC OnLine All 1294] which captures with precision the scope of the concerned provision and more significantly, the import of the phrase

SHRI RAMESH BATTA,DEHRADUN vs. ACIT, DEHRADUN

In the result, appeal of the Assessee in both the cases are allowed and appeal filed by the Revenue in both the cases are dismissed

ITA 2163/DEL/2017[2008-09]Status: DisposedITAT Dehradun21 Feb 2025AY 2008-09

Bench: Shri Anubhav Sharma & Shri Manish Agarwalacit, Shri Ramesh Batta Central Circle, 81/210, Kaulagarh Road, Vs. Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Shri Ramesh Batta Dy. Cit, 81/210, Kaulagarh Central Circle, Vs. Road, Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Acit, Shri Ramesh Batta, Central Circle, As Agent Of Smt. Kavita Vs. Dehradun. Ahuja, 81/210, Kaulagarh Road, Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent)

Section 143(2)Section 153ASection 153D

b) of sub-section (1) of Section 153A of the Act. It is beneficial to refer to the decision of the High Court of Judicature at Allahabad in the case of PCIT v. Sapna Gupta [2022 SCC OnLine All 1294] which captures with precision the scope of the concerned provision and more significantly, the import of the phrase

DCIT, DEHRADUN vs. SH. RAMESH BATTA AS AGENT OF SMT. KAVITA AHUJA, DEHRADUN

In the result, appeal of the Assessee in both the cases are allowed and appeal filed by the Revenue in both the cases are dismissed

ITA 4854/DEL/2016[2008-09]Status: DisposedITAT Dehradun21 Feb 2025AY 2008-09

Bench: Shri Anubhav Sharma & Shri Manish Agarwalacit, Shri Ramesh Batta Central Circle, 81/210, Kaulagarh Road, Vs. Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Shri Ramesh Batta Dy. Cit, 81/210, Kaulagarh Central Circle, Vs. Road, Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Acit, Shri Ramesh Batta, Central Circle, As Agent Of Smt. Kavita Vs. Dehradun. Ahuja, 81/210, Kaulagarh Road, Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent)

Section 143(2)Section 153ASection 153D

b) of sub-section (1) of Section 153A of the Act. It is beneficial to refer to the decision of the High Court of Judicature at Allahabad in the case of PCIT v. Sapna Gupta [2022 SCC OnLine All 1294] which captures with precision the scope of the concerned provision and more significantly, the import of the phrase

DCIT, CIRCLE- I, INTERNATIONAL TAXATION, DEHRADUN vs. EXPRESS DRILLING SYSTEMS LLC, DEHRADUN

In the result, cross objection filed by the assessee is partly

ITA 6114/DEL/2017[2009-10]Status: DisposedITAT Dehradun26 Sept 2023AY 2009-10

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

Section 143(3)Section 144CSection 234BSection 40

b) "eligible assessee" means,— (i) any person in whose case the variation referred to in sub-section (1) arises as a consequence of the order of the Transfer Pricing Officer passed under sub-section (3) of section 92CA ; and (ii) any non-resident not being a company, or any foreign company," 17. In the opinion of this

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DEHRADUN, CROSS ROAD vs. RAJU VERMA, CURZON ROAD, DALANWALA

In the result, the appeal of the assessee is allowed

ITA 6/DDN/2024[2010-11]Status: DisposedITAT Dehradun02 Apr 2025AY 2010-11

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh

For Appellant: Shri K. K. Juneja, AdvFor Respondent: Shri S. K. chaterjee, CIT DR
Section 1Section 153Section 153ASection 153D

3. You are directed to pass necessary order, In the above cases for all the relevant years. This office letter approving the draft orders shall invariably be mentioned in the final orders. A copy of final order passed in these cases shall be sent to this office for record 4. Further, In the case of Sh. Satish Charider Kapoor, further

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DEHRADUN, CROSS ROAD vs. RAJU VERMA, CURZON ROAD

In the result, the appeal of the assessee is allowed

ITA 11/DDN/2024[2011]Status: DisposedITAT Dehradun02 Apr 2025

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh

For Appellant: Shri K. K. Juneja, AdvFor Respondent: Shri S. K. chaterjee, CIT DR
Section 1Section 153Section 153ASection 153D

3. You are directed to pass necessary order, In the above cases for all the relevant years. This office letter approving the draft orders shall invariably be mentioned in the final orders. A copy of final order passed in these cases shall be sent to this office for record 4. Further, In the case of Sh. Satish Charider Kapoor, further

RAJU VERMA,DEHRADUN vs. DCIT, DEHRADUN

In the result, the appeal of the assessee is allowed

ITA 1809/DEL/2017[2012-13]Status: DisposedITAT Dehradun21 Feb 2025AY 2012-13

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

Section 153Section 153ASection 153D

3. You are directed to pass necessary order, In the above cases for all the relevant years. This office letter approving the draft orders shall invariably be mentioned in the final orders. A copy of final order passed in these cases shall be sent to this office for record 4. Further, In the case of Sh. Satish Chander Kapoor, further