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
ITA 5305/DEL/2018[2015-16]Status: DisposedITAT Dehradun15 Sept 2023AY 2015-16
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
For Appellant: Shri P. J. Pardiwalla, Sr. AdvFor Respondent: Shri Mayank Kumar, JCIT, DR
Section 143(3)Section 44BSection 9(1)(vii)
71,88,592/-.
However, with regard to the contracts mentioned in Serial Numbers 216 to 231, the ld. AO observed that the said services to be taxed as fees for technical services u/s 9(1)(vii) of the Act and accordingly the provisions of section 44DA of the Act on net income basis would have to be applied
