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 2

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 2

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 2

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 2

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 2

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 2

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

ITO, DEHRADUN vs. M/S. UNISON DEVELOPERS PVT. LTD., DEHRADUN

In the result, the appeal of the Revenue is dismissed

Bench: Shri Saktijit Dey & Shri M. Balaganeshassessment Year: 2007-08 Ito, Vs Unison Developers Pvt. Ltd., Ward-2(5), C/O Virendra Kalra & Co., Cas, 13A, Subhash Road, 75/7, Rajpur Road, Dehradun. Dehradun. Pan: Aaacu7259C (Applicant) (Respondent) Assessee By : Shri Virendra Kalra, Ca Revenue By : Smt. Poonam Sharma, Addl. Cit Date Of Hearing : 24.04.2023 Date Of Pronouncement : 03.05.2023 Order Per M. Balaganesh, Am: This Appeal In Ita No.25/Ddn/2017 For Ay 2007-08 Arises Out Of The Order Of The Ld. Commissioner Of Income Tax (Appeals), Dehradun In Appeal No.584/Cit(A)/Ddn/2015-16 Dated 28.10.2016 [Hereinafter Referred To As ‘Ld. Cit(A)’, In Short] Against The Order Of Assessment Passed U/S 143(3)/148 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Dated 31.03.2016 By The Ld. Income-Tax Officer, Ward-2(5), Dehradun (Hereinafter Referred To As ‘Ld. Ao’). 2. The Revenue Has Raised The Following Grounds:- “1. The Ld. Cit(A), Dehradun Has Erred In Law & On Facts In Quashing The Issue Of Notice U/S 148 Rendering The Entire Proceedings As Void-Ab-Initio. 2. The Ld. Cit(A) Has Erred In Law & On The Facts Of The Case In Deleting The Addition Made In The Hands Of The Company On Account Of Share Application Money Which Had Alrightly Been Assessed As Unaccounted Income Of The Assessee Company U/S 68 Of I.T. Act, 1961. 3. The Order Of Ld. Cit (A) Be Set-A-Side Being Erroneous In Law & On Facts & That Of Ao May Be Restored.”

35,00,000/- was provided to the assessee during the financial year 2007-08 relevant to AY 2008-09. The ld. AO observed that the assessee has received share application money amounting to Rs.2,15,00,000/- during the year under consideration from the following parties:- Name & Address of the Share No. of shares Date of allotment application allotted. Applicant

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

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

2 of final assessment order wherein the details of various expenses incurred by Branch Office and various project office has been tabulated . 32 . The ld . CIT DR opposed for the same. However, could not controvert the above reproduced observation by this Tribunal in assessee’s own case for earlier years . 33 . We have heard the rival submissions and perused

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

2 Sumit Verma AEKPV4635E 2006-2007 To 2012-13 3 Poonam Verma ACQPD3112N 2006-2007 To 2012-13 4 Ritu Verma AAOPV3196Q 2006-2007 To 2012-13 5 Ganpati Builders AAEFG6241R 2006-2007 To 2012-13 3. You are directed to pass necessary order, In the above cases for all the relevant years. This office letter approving the draft orders

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

2 Sumit Verma AEKPV4635E 2006-2007 To 2012-13 3 Poonam Verma ACQPD3112N 2006-2007 To 2012-13 4 Ritu Verma AAOPV3196Q 2006-2007 To 2012-13 5 Ganpati Builders AAEFG6241R 2006-2007 To 2012-13 3. You are directed to pass necessary order, In the above cases for all the relevant years. This office letter approving the draft orders

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)

2 Sumit Verma AEKPV4635E 2006-2007 To 2012-13 3 Poonam Verma ACQPD3112N 2006-2007 To 2012-13 4 Ritu Verma AAOPV3196Q 2006-2007 To 2012-13 5 Ganpati Builders AAEFG6241R 2006-2007 To 2012-13 3. You are directed to pass necessary order, In the above cases for all the relevant years. This office letter approving the draft orders