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

section 234A of the Act, amounting to Rs.4,125,414.” 63. We first come to the appeal of the assessee. Per ground number 1 – 4, the assessee has challenged the taxability of revenue from offshore supply of imported material. Both the parties confirm that this is identical to ground number 1 – 2 of the appeal of the assessee

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

section 234A of the Act, amounting to Rs.4,125,414.” 63. We first come to the appeal of the assessee. Per ground number 1 – 4, the assessee has challenged the taxability of revenue from offshore supply of imported material. Both the parties confirm that this is identical to ground number 1 – 2 of the appeal of the assessee

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

section 234A of the Act, amounting to Rs.4,125,414.” 63. We first come to the appeal of the assessee. Per ground number 1 – 4, the assessee has challenged the taxability of revenue from offshore supply of imported material. Both the parties confirm that this is identical to ground number 1 – 2 of the appeal of the assessee

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

section 234A of the Act, amounting to Rs.4,125,414.” 63. We first come to the appeal of the assessee. Per ground number 1 – 4, the assessee has challenged the taxability of revenue from offshore supply of imported material. Both the parties confirm that this is identical to ground number 1 – 2 of the appeal of the assessee

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

section 234A of the Act, amounting to Rs.4,125,414.” 63. We first come to the appeal of the assessee. Per ground number 1 – 4, the assessee has challenged the taxability of revenue from offshore supply of imported material. Both the parties confirm that this is identical to ground number 1 – 2 of the appeal of the assessee

DCIT, CC, , DEHRADUN vs. SRIVAAS PROJECTS PRIVATE LTD, RISHIKESH

Bench: Shri Saktijit Dey, Vice- & Shri M. Balaganesh

44,08,000/-, being share premium, to the income of the assessee under section 68 of the Act. 6. The assessee

SRIVAAS PROJECTS PRIVATE LTD,NEW DELHI vs. DCIT, CC, , DEHRADUN

Bench: Shri Saktijit Dey, Vice- & Shri M. Balaganesh

44,08,000/-, being share premium, to the income of the assessee under section 68 of the Act. 6. The assessee

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

44. Thus the first common issue raised in all these appeals relating to deduction under section 80IB(10) is decided in favour of the assessees and the orders of the Commissioner of Income- tax(Appeals) on this issue is upheld on the ground that the returns filed under section 153A are returns filed under section

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

section 44DA of the Act on net income basis would have to be applied. ITA No. 6126/Del/2017 & ITA No. 5223/Del/2018 (Assessee) ITA No. 6173/Del/2017 & ITA No. 5305/Del/2018 (Revenue) Schlumberger Asia Services Ltd The ld. AO observed that these services cannot be considered as any activity relating to mining activity as in the opinion of the ld. AO, in these

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

section 44DA of the Act on net income basis would have to be applied. ITA No. 6126/Del/2017 & ITA No. 5223/Del/2018 (Assessee) ITA No. 6173/Del/2017 & ITA No. 5305/Del/2018 (Revenue) Schlumberger Asia Services Ltd The ld. AO observed that these services cannot be considered as any activity relating to mining activity as in the opinion of the ld. AO, in these

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

section 44DA of the Act on net income basis would have to be applied. ITA No. 6126/Del/2017 & ITA No. 5223/Del/2018 (Assessee) ITA No. 6173/Del/2017 & ITA No. 5305/Del/2018 (Revenue) Schlumberger Asia Services Ltd The ld. AO observed that these services cannot be considered as any activity relating to mining activity as in the opinion of the ld. AO, in these

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

section 44DA of the Act on net income basis would have to be applied. ITA No. 6126/Del/2017 & ITA No. 5223/Del/2018 (Assessee) ITA No. 6173/Del/2017 & ITA No. 5305/Del/2018 (Revenue) Schlumberger Asia Services Ltd The ld. AO observed that these services cannot be considered as any activity relating to mining activity as in the opinion of the ld. AO, in these

REENA VERMA,HARIDWAR vs. ITO, WARD-1(3)(5), ROORKEE

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

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

section 145(3) of the Act and applied net profit @ 8% of the annual sale of Rs.1,44,77,740/- as under: “4.12 As per return of income filed by the assessee, a turnover of Rs.1,44,77,740/- has been shown. After claiming various expenses, a net profit of Rs.2,86,150/- has been shown against the turnover

INTECSEA ASIA PACIFIC SDN BHD,MALAYSIA vs. ACIT, INTERNATIONAL TAXATION, CIRCLE- 1, DEHRADUN

The appeal of the assessee is allowed

Bench: Shri Amit Shukla & Shri B.R.R. Kumarasstt. Year : 2015-16 Intecsea Asia Pacific N Vs. Acit, International Bhd Taxation, Circle-1, Kpmg Salarpuria Knowledge Dehradun City, Orwell Unit 3, 6Th Floor Sy. No. 83/2, Plot 2, Raidurg, Hyderabad 500081 (Appellant) (Respondent)

44 DA of the Act. 5.22 In view of the above discussion, it is held that the entire receipts of the Appellant in the case of ONGC are taxable under section 44DA the Act. Receipts from M/s Leighton India is taxable under section 44BB and section 44DA of the Act, as per the discussions between Para

ACIT, CIRCLE- II, INTERNATIONAL TAXATION , DEHRADUN vs. WEATHERFORD OIL TOOLS M.E. LTD., DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

68,74,954 as the income attributable to the Appellants PE from offshore supply of goods and thereby confirming the addition of INR 34,20,203. Ground No. 2 That on the facts and in the circumstances of the case and in law the Ld CIT(A) erred in arbitrary applying the 3 ITA Nos. 7334, 7477 & 7848/Del./2017

WEATHERFORD OIL TOOLS M.E. LTD.,NOIDA vs. DCIT, CIRCLE- 2, INTERNATIONAL TAXATION, DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

68,74,954 as the income attributable to the Appellants PE from offshore supply of goods and thereby confirming the addition of INR 34,20,203. Ground No. 2 That on the facts and in the circumstances of the case and in law the Ld CIT(A) erred in arbitrary applying the 3 ITA Nos. 7334, 7477 & 7848/Del./2017

ACIT, CIRCLE- II, INTERNATIONAL TAXATION, DEHRADUN vs. WEATHERFORD OIL TOOLS ME LTD., DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

68,74,954 as the income attributable to the Appellants PE from offshore supply of goods and thereby confirming the addition of INR 34,20,203. Ground No. 2 That on the facts and in the circumstances of the case and in law the Ld CIT(A) erred in arbitrary applying the 3 ITA Nos. 7334, 7477 & 7848/Del./2017

ACIT, CIRCLE- II, INTERNATIONAL TAXATION, DEHRADUN vs. WEATHERFORD OIL TOOLS M.E. LTD., DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

68,74,954 as the income attributable to the Appellants PE from offshore supply of goods and thereby confirming the addition of INR 34,20,203. Ground No. 2 That on the facts and in the circumstances of the case and in law the Ld CIT(A) erred in arbitrary applying the 3 ITA Nos. 7334, 7477 & 7848/Del./2017