DEPUTY COMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DEHRADUN, DEHRADUN vs. KAMAL JEWELLERS, DEHRADUN

In the result, Appeal of the Revenue in ITA

Bench: Sh. Yogesh Kumar Us & Sh. Manish Agarwal

35, Kamal Market, Dhamawala, Central Circle, Dehradun-248001 Dehradun, Uttarakhand-248001 (APPELLANT) (RESPONDENT) PAN No. AAPFK0688M Assessee by: Sh. Rajiv Sahini, CA Revenue by: Ms. Poonam Sharma, CIT-DR Date of Hearing: 09.12.2025 Date of Pronouncement: 14 .01.2026 ORDER PER YOGESH KUMAR U.S., JUDICIAL MEMBER: The present appeal is filed by the Revenue and the Cross Objection by the assessee

INCOME TAX OFFICER, WARD 1(1)(2), DEHRADUN, DEHRADUN vs. MAHALAXMI BUILDWELL, DEHRADUN

Appeal is dismissed in above terms

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh(Through Video Conferencing) Assessment Year: 2015-16 Income Tax Officer, Vs. Mahalaxmi Buildwell, Ward-1(1)(2), 118, Subhash Road, Dehradun Dehradun Pan :Aazfm1835G (Appellant) (Respondent) Assessee By Sh. Mayank Kumar Aggarwal, Ca Department By Sh. A.S. Rana, Sr. Dr

section 68 addition of unexplained cash credits to the tune of Rs.3.16 crores; reading as under: “4. During the course of appellate proceedings, the appellant furnished the written submission and the following documents: 1. Bank Account Statement 2. Copy of sale deed of the property purchased 3. Balance Sheet of the firm as on 31.03.2015 4. Confirmation Statement

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

35. In view of this appeal of the learned assessing officer for assessment year 2007 – 08 in ITA number 5564/Del/2013 is dismissed. 36. Coming to the appeal of the assessee, ground number 1 is with respect to the initiation of reassessment proceedings, no arguments were advanced before us, therefore this ground of appeal is dismissed. 37. Ground number

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

35. In view of this appeal of the learned assessing officer for assessment year 2007 – 08 in ITA number 5564/Del/2013 is dismissed. 36. Coming to the appeal of the assessee, ground number 1 is with respect to the initiation of reassessment proceedings, no arguments were advanced before us, therefore this ground of appeal is dismissed. 37. Ground number

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

35. In view of this appeal of the learned assessing officer for assessment year 2007 – 08 in ITA number 5564/Del/2013 is dismissed. 36. Coming to the appeal of the assessee, ground number 1 is with respect to the initiation of reassessment proceedings, no arguments were advanced before us, therefore this ground of appeal is dismissed. 37. Ground number

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

35. In view of this appeal of the learned assessing officer for assessment year 2007 – 08 in ITA number 5564/Del/2013 is dismissed. 36. Coming to the appeal of the assessee, ground number 1 is with respect to the initiation of reassessment proceedings, no arguments were advanced before us, therefore this ground of appeal is dismissed. 37. Ground number

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

35. In view of this appeal of the learned assessing officer for assessment year 2007 – 08 in ITA number 5564/Del/2013 is dismissed. 36. Coming to the appeal of the assessee, ground number 1 is with respect to the initiation of reassessment proceedings, no arguments were advanced before us, therefore this ground of appeal is dismissed. 37. Ground number

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

35. In view of this appeal of the learned assessing officer for assessment year 2007 – 08 in ITA number 5564/Del/2013 is dismissed. 36. Coming to the appeal of the assessee, ground number 1 is with respect to the initiation of reassessment proceedings, no arguments were advanced before us, therefore this ground of appeal is dismissed. 37. Ground number

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

35. In view of this appeal of the learned assessing officer for assessment year 2007 – 08 in ITA number 5564/Del/2013 is dismissed. 36. Coming to the appeal of the assessee, ground number 1 is with respect to the initiation of reassessment proceedings, no arguments were advanced before us, therefore this ground of appeal is dismissed. 37. Ground number

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 . The ld . CIT DR has no objection for the above issue to be set aside to ld . AO/TPO. 69 . After hearing both the sides and considering the totality of the facts of the case, we deem it proper to restore the issue to the file of the Assessing Officer with a direction to give an opportunity to the assessee

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

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh

35 assessment years. The approval in all the cases was sought vide letter dated 13.3.2014 by the DCIT, Central Circle, Dehradun and approval was granted by a single order on 24.3.2014 by the Addl. CIT, Range Central, Meerut. It was the submission that a perusal of the approval granted clearly shows that the same is given in mechanical manner where

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

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh

35 assessment years. The approval in all the cases was sought vide letter dated 13.3.2014 by the DCIT, Central Circle, Dehradun and approval was granted by a single order on 24.3.2014 by the Addl. CIT, Range Central, Meerut. It was the submission that a perusal of the approval granted clearly shows that the same is given in mechanical manner where

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

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

RAJU VERMA,DEHRADUN vs. DCIT, DEHRADUN

In the result, the appeal of the assessee is allowed

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

35 assessment years. The approval in all the cases was sought vide letter dated 13.3.2014 by the DCIT, Central Circle, Dehradun and approval was granted by a single order on 24.3.2014 by the Addl. CIT, Range Central, Meerut. It was the submission that a perusal of the approval granted clearly shows that the same is given in mechanical manner where