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

32. The learned AO has raised the following grounds of appeal in ITA No. 5564/Del/2013 for the Assessment Year 2007-08:- “1. Whether on the facts and circumstances of the case, the Ld CIT(A) has erred in holding that no distinction can be made between receipts from PSC and Non-PSC Partners, ignoring the facts that the receipts from

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

32. The learned AO has raised the following grounds of appeal in ITA No. 5564/Del/2013 for the Assessment Year 2007-08:- “1. Whether on the facts and circumstances of the case, the Ld CIT(A) has erred in holding that no distinction can be made between receipts from PSC and Non-PSC Partners, ignoring the facts that the receipts from

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

32. The learned AO has raised the following grounds of appeal in ITA No. 5564/Del/2013 for the Assessment Year 2007-08:- “1. Whether on the facts and circumstances of the case, the Ld CIT(A) has erred in holding that no distinction can be made between receipts from PSC and Non-PSC Partners, ignoring the facts that the receipts from

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

32. The learned AO has raised the following grounds of appeal in ITA No. 5564/Del/2013 for the Assessment Year 2007-08:- “1. Whether on the facts and circumstances of the case, the Ld CIT(A) has erred in holding that no distinction can be made between receipts from PSC and Non-PSC Partners, ignoring the facts that the receipts from

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

32. The learned AO has raised the following grounds of appeal in ITA No. 5564/Del/2013 for the Assessment Year 2007-08:- “1. Whether on the facts and circumstances of the case, the Ld CIT(A) has erred in holding that no distinction can be made between receipts from PSC and Non-PSC Partners, ignoring the facts that the receipts from

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

32. The learned AO has raised the following grounds of appeal in ITA No. 5564/Del/2013 for the Assessment Year 2007-08:- “1. Whether on the facts and circumstances of the case, the Ld CIT(A) has erred in holding that no distinction can be made between receipts from PSC and Non-PSC Partners, ignoring the facts that the receipts from

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

32. The learned AO has raised the following grounds of appeal in ITA No. 5564/Del/2013 for the Assessment Year 2007-08:- “1. Whether on the facts and circumstances of the case, the Ld CIT(A) has erred in holding that no distinction can be made between receipts from PSC and Non-PSC Partners, ignoring the facts that the receipts from

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

32. How the requirement of section 139(1) is satisfied by filing a return under section 153A? This is assumed in the light of section 153A(1)(a), where it is stated that where a search is initiated under section 132, the Assessing Officer shall issue notice to such person requiring him to furnish within such

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

2 to 8 of the assessment order. 4.2. During the year, the assessee derived revenues from the various contracts amounting to Rs 1933,20,29,195/- and offered to tax u/s 44BB of the Act on presumptive basis @ 10% of receipts amounting to Rs 193,32,02,920/-. 4.3. We find that there is absolutely no dispute that the assessee

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

2 to 8 of the assessment order. 4.2. During the year, the assessee derived revenues from the various contracts amounting to Rs 1933,20,29,195/- and offered to tax u/s 44BB of the Act on presumptive basis @ 10% of receipts amounting to Rs 193,32,02,920/-. 4.3. We find that there is absolutely no dispute that the assessee

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

2 to 8 of the assessment order. 4.2. During the year, the assessee derived revenues from the various contracts amounting to Rs 1933,20,29,195/- and offered to tax u/s 44BB of the Act on presumptive basis @ 10% of receipts amounting to Rs 193,32,02,920/-. 4.3. We find that there is absolutely no dispute that the assessee

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

2 to 8 of the assessment order. 4.2. During the year, the assessee derived revenues from the various contracts amounting to Rs 1933,20,29,195/- and offered to tax u/s 44BB of the Act on presumptive basis @ 10% of receipts amounting to Rs 193,32,02,920/-. 4.3. We find that there is absolutely no dispute that the assessee

MUSSORIE DEHRADUN DEVELOPMENT AUTHORITY ,DEHRADUN vs. DY.CIT, DEHRADUN

In the result, the appeal of the assessee is partly allowed as above

Bench: the date of agreement. In his reply AR of the assessee submitted that only Rs.14,00,415/- was received during the year and the assessee has inadvertently forgot to include this amount in its income. So, this may be considered as income from transfer of the above property. He furnished receipt of the above amount which is place on record. MDDA

2 MDDA Sub-section 4 of section 43CA clearly states that the provisions of sub-section (3) shall apply only in a case where the amount of consideration or a part thereof has been received by any mode other than cash on or before the date of agreement for transfer of the asset. But the assessee

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

68,009/- worked/determined out/by the auditor appointed by the Revenue. The Ld. Counsel contended that the Revenue had taken all the adverse findings pointed out by the auditor appointed by the Revenue but not the loss determined by the auditor appointed by the Revenue. It was submitted that since the loss worked/determined out/by the auditor happened to be more than

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

68,009/- worked/determined out/by the auditor appointed by the Revenue. The Ld. Counsel contended that the Revenue had taken all the adverse findings pointed out by the auditor appointed by the Revenue but not the loss determined by the auditor appointed by the Revenue. It was submitted that since the loss worked/determined out/by the auditor happened to be more than

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

In the result, appeal of the Revenue is dismissed

32% to 40%. It is also noticed that the appellant firm follows\na consistent practice of depositing and withdrawing cash from the bank accounts and\nthe cash withdrawals in the present cash are done as per routine and to conduct\nnormal business activities of the appellant firm and for incurring the day-to-day\nbusiness expenses,\n\n5.1.5

KRISHNA KUMAR AGARWAL,DEHRADUN vs. ITO, UTTRAKHAND

Appeal is partly allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal(Through Video Conferencing) Assessment Year: 2011-12 Sh. Krishna Kumar Agarwal, Vs. Income Tax Officer, M/S. Kumaon Brick Field, Ward-Khatima C./O- Adv. N.R. Goel, 32 E.C. Road, Dehradun, Uttarakhand Pan :Afqpa1977B (Appellant) (Respondent) Assessee By Ms. Shilpa Gupta, Ca Department By Sh. A.S. Rana, Sr. Dr

32 E.C. Road, Dehradun, Uttarakhand PAN :AFQPA1977B (Appellant) (Respondent) Assessee by Ms. Shilpa Gupta, CA Department by Sh. A.S. Rana, Sr. DR Date of hearing 12.01.2026 Date of pronouncement 12.01.2026 ORDER PER SATBEER SINGH GODARA, JM: This assessee’s appeal for assessment year 2011-12, arises against the Commissioner of Income Tax (Appeals)-II [in short, the “CIT(A)”], Dehradun

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

68,11,169. However, the disallowances totaling to Rs. 2,12,426 have been suo-moto made by the assessee. Therefore, to prevent double addition, the difference of Rs. 8,65,98,743 was added by the AO to the total income. The AO proposed to disallow the expenses by alleging that since the said expenses had been incurred

DCIT, CENTRAL CIRCLE, DEHRADUN vs. SWARNGANGA CONSTRUCTION P.LTD, BHILWARA

In the result, both the appeals of the revenue are allowed for statistical purposes

Bench: Shri R.K. Panda & Shri V.P. Rao

section 144 and penalty order u/s. 271(1)(c) of the Act respectively for the assessment year 2012-13. 2. In the quantum appeal, the assessee raised following grounds : “1. On facts and circumstances of the case and in law, the Ld. CIT(A) erred in condoning the delay of more than 2 years merely on ground that