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

b. The learned CIT(A) has erred in not appreciating that acceptance of PAR was essential to adjudicate the issue of taxability of offshore supply of imported material on fair and just basis. c. The learned CIT(A) has erred in not considering the PAR merely on the basis that contracts are composite contracts involving supply of material and rendering

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

b. The learned CIT(A) has erred in not appreciating that acceptance of PAR was essential to adjudicate the issue of taxability of offshore supply of imported material on fair and just basis. c. The learned CIT(A) has erred in not considering the PAR merely on the basis that contracts are composite contracts involving supply of material and rendering

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

b. The learned CIT(A) has erred in not appreciating that acceptance of PAR was essential to adjudicate the issue of taxability of offshore supply of imported material on fair and just basis. c. The learned CIT(A) has erred in not considering the PAR merely on the basis that contracts are composite contracts involving supply of material and rendering

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

b. The learned CIT(A) has erred in not appreciating that acceptance of PAR was essential to adjudicate the issue of taxability of offshore supply of imported material on fair and just basis. c. The learned CIT(A) has erred in not considering the PAR merely on the basis that contracts are composite contracts involving supply of material and rendering

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

b. The learned CIT(A) has erred in not appreciating that acceptance of PAR was essential to adjudicate the issue of taxability of offshore supply of imported material on fair and just basis. c. The learned CIT(A) has erred in not considering the PAR merely on the basis that contracts are composite contracts involving supply of material and rendering

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

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)

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

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)

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

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)

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

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)

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

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

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

6. 5647/Del/2018 DCIT Weatherford CIT(A)-2, Noida, 143(3)/144C Oil Tools ME A.Y. 2015-16 Appeal No. 93/CIT(A)- (3)(b) Ltd. 2 /2017-18/Noida Dated 22.06.2018 2. Heard both the parties at length. Case file perused. We proceed assessment year wise for the sake of convenience and brevity. A.Y. 2013-14 ITA No. 7477/Del/2017 (Revenue’s cross appeal

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

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

6. 5647/Del/2018 DCIT Weatherford CIT(A)-2, Noida, 143(3)/144C Oil Tools ME A.Y. 2015-16 Appeal No. 93/CIT(A)- (3)(b) Ltd. 2 /2017-18/Noida Dated 22.06.2018 2. Heard both the parties at length. Case file perused. We proceed assessment year wise for the sake of convenience and brevity. A.Y. 2013-14 ITA No. 7477/Del/2017 (Revenue’s cross appeal

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

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

6. 5647/Del/2018 DCIT Weatherford CIT(A)-2, Noida, 143(3)/144C Oil Tools ME A.Y. 2015-16 Appeal No. 93/CIT(A)- (3)(b) Ltd. 2 /2017-18/Noida Dated 22.06.2018 2. Heard both the parties at length. Case file perused. We proceed assessment year wise for the sake of convenience and brevity. A.Y. 2013-14 ITA No. 7477/Del/2017 (Revenue’s cross appeal

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

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

6. 5647/Del/2018 DCIT Weatherford CIT(A)-2, Noida, 143(3)/144C Oil Tools ME A.Y. 2015-16 Appeal No. 93/CIT(A)- (3)(b) Ltd. 2 /2017-18/Noida Dated 22.06.2018 2. Heard both the parties at length. Case file perused. We proceed assessment year wise for the sake of convenience and brevity. A.Y. 2013-14 ITA No. 7477/Del/2017 (Revenue’s cross appeal

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

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

6. 5647/Del/2018 DCIT Weatherford CIT(A)-2, Noida, 143(3)/144C Oil Tools ME A.Y. 2015-16 Appeal No. 93/CIT(A)- (3)(b) Ltd. 2 /2017-18/Noida Dated 22.06.2018 2. Heard both the parties at length. Case file perused. We proceed assessment year wise for the sake of convenience and brevity. A.Y. 2013-14 ITA No. 7477/Del/2017 (Revenue’s cross appeal

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

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

6. 5647/Del/2018 DCIT Weatherford CIT(A)-2, Noida, 143(3)/144C Oil Tools ME A.Y. 2015-16 Appeal No. 93/CIT(A)- (3)(b) Ltd. 2 /2017-18/Noida Dated 22.06.2018 2. Heard both the parties at length. Case file perused. We proceed assessment year wise for the sake of convenience and brevity. A.Y. 2013-14 ITA No. 7477/Del/2017 (Revenue’s cross appeal

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)

b) for the assessment year 2015-16. In the grounds of appeal assessee has raised following grounds:- “1.On the facts and in the circumstance of the case and in law, the Assistant Commissioner of Income Tax, International Taxation, Circle-1, Dehradun (‘Ld. AO’) and the Learned Commissioner of Income Tax (Appeals) - II, Noida [‘Ld. CIT(A)’] erred in concluding that

ACHARYA BALKRISHNA,HARIDWAR vs. DCIT, DEHRADUN

In the result appeal of the assessee is allowed

Bench: SHRI YOGESH KUMAR U.S. (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

68 as unexplained cash credits and Rs. 1,25,000/- as unexplained expenditure u/s 69C for obtaining such loan were made in the hands of the assessee. Against the said order an appeal was filed before the Ld. CIT(A) who dismissed the appeal of the assessee. 3. Aggrieved by the said order, assessee is in appeal before the Tribunal

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

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

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

2) by the eligible assessee. (14A) The provisions of this section shall not apply to any assessment or reassessment order passed by the Assessing Officer with the prior approval of the Principal Commissioner or Commissioner as provided in sub-section (12) of section 144BA. (15) For the purposes of this section,— (a) "Dispute Resolution Panel" means