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

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

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

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

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

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

DCIT, CENTRAL CIRCLE, DEHRADUN vs. SWARNGANGA CONSTRUCTION P.LTD, BHILWARA

In the result, both the appeals of the revenue are allowed for statistical purposes

Bench: Shri R.K. Panda & Shri V.P. Rao

68 of the act by submitting cogent documentary evidences. Hence, addition on this count is unwarranted. (C) Page No. 71 to 76 containing the transaction of Rs. 50,00,000/- by the appellant company being loan given to M/s. KamyaRealinvestPvt.Ltd. This page pertain to loan of Rs. 50,00,000/- advanced to M/s. KamyaRealinvestPvt. Ltd.. The confirmation from loanee

DCIT, DEHRADUN vs. INTECSEA ASIA PACIFIC SDN BHD, HYDERABAD

The appeal of the assessee is allowed

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 152/Ddn/2025 : Asstt. Year: 2016-17 Ita No. 153/Ddn/2025 : Asstt. Year: 2018-19 Dcit, Vs Intecsea Asia Pacific Sdn Bhd, 13A, Subhash Road, Income Road No. 11, Barijara Hills, Tax Officer, Dehradun-248001 Hyderabad-500034 (Appellant) (Respondent) Pan No. Aabci3002L Assessee By : Sh. Siddesh Choudhary, Adv. Revenue By : Sh. Mohan Lal Joshi, Sr. Dr Date Of Hearing: 13.01.2026 Date Of Pronouncement: 13.01.2026 Order Per Satbeer Singh Godara: These Revenue’S Twin Appeals

68 taxmann.com 143)];  DIT vs. Jindal Drilling & Industries Ltd. [(2009) (182 Taxman 59)];  Siem Offshore Inc, In re. [(2011) 12 taxmann.com 374] 12. Apart from above, he also relied upon the following decisions in support of its clam that consideration received for services rendered in connection with prospecting, extraction or production of mineral oils shall be taxable under section

DCIT, DEHRADUN vs. INTECSEA ASIA PACIFIC SDN BHD, HYDERABAD

The appeal of the assessee is allowed

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 152/Ddn/2025 : Asstt. Year: 2016-17 Ita No. 153/Ddn/2025 : Asstt. Year: 2018-19 Dcit, Vs Intecsea Asia Pacific Sdn Bhd, 13A, Subhash Road, Income Road No. 11, Barijara Hills, Tax Officer, Dehradun-248001 Hyderabad-500034 (Appellant) (Respondent) Pan No. Aabci3002L Assessee By : Sh. Siddesh Choudhary, Adv. Revenue By : Sh. Mohan Lal Joshi, Sr. Dr Date Of Hearing: 13.01.2026 Date Of Pronouncement: 13.01.2026 Order Per Satbeer Singh Godara: These Revenue’S Twin Appeals

68 taxmann.com 143)];  DIT vs. Jindal Drilling & Industries Ltd. [(2009) (182 Taxman 59)];  Siem Offshore Inc, In re. [(2011) 12 taxmann.com 374] 12. Apart from above, he also relied upon the following decisions in support of its clam that consideration received for services rendered in connection with prospecting, extraction or production of mineral oils shall be taxable under section

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)

68 taxmann.com 143)]; • DIT vs. Jindal Drilling & Industries Ltd. [(2009) (182 Taxman 59)]; • Siem Offshore Inc, In re. [(2011) 12 taxmann.com 374] 12. Apart from above, he also relied upon the following decisions in support of its clam that consideration received for services rendered in connection with prospecting, extraction or production of mineral oils shall be taxable under section

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 of the assessee is partly allowed

Bench: Shri R.K. Panda & Shri V.P. Raoassessment Years: 2016-17

71,20,459 on the basis that the Appellant submitted only internal documents which do not suffice for allowance of expenditure. 11.2 The learned AO / DRP erred in not appreciating that amount of obsolete inventory written off was debited to the Profit and Loss Account which has been audited by an independent auditor. Ground No. 12: Claim for deduction

SH.SURENDER KUMAR CHAWLA,RUDRAPUR vs. ACIT , CC, HALDWANI, HALDWANI

In the result, assessee’s appeals; ITA No

Bench: BEFORESHRI CHALLA NAGENDRA PRASAD (Judicial Member), SHRI AVDHESH KUMAR MISHRA (Accountant Member)

71,000/- on account of alleged purchase of property from Mr. Mohan Pal as alleged unexplained investment u/s 69 of the Income Tax Act, 1961. 7. The learned assessing officer as also learned CIT(A) have erred in making and confirming addition of Rs.2,94,00,000/- on account of alleged purchase of property from Mr. Mohan Pal as alleged

SH. SURENDER KUMAR CHAWLA,RUDRAPUR vs. ACIT, CC, , HALDWANI

In the result, assessee’s appeals; ITA No

Bench: BEFORESHRI CHALLA NAGENDRA PRASAD (Judicial Member), SHRI AVDHESH KUMAR MISHRA (Accountant Member)

71,000/- on account of alleged purchase of property from Mr. Mohan Pal as alleged unexplained investment u/s 69 of the Income Tax Act, 1961. 7. The learned assessing officer as also learned CIT(A) have erred in making and confirming addition of Rs.2,94,00,000/- on account of alleged purchase of property from Mr. Mohan Pal as alleged

SH. SURENDER KUMAR CHAWLA,RUDRAPUR vs. ACIT, CC-, HALDWANI, HALDWANI

In the result, assessee’s appeals; ITA No

Bench: BEFORESHRI CHALLA NAGENDRA PRASAD (Judicial Member), SHRI AVDHESH KUMAR MISHRA (Accountant Member)

71,000/- on account of alleged purchase of property from Mr. Mohan Pal as alleged unexplained investment u/s 69 of the Income Tax Act, 1961. 7. The learned assessing officer as also learned CIT(A) have erred in making and confirming addition of Rs.2,94,00,000/- on account of alleged purchase of property from Mr. Mohan Pal as alleged

SH.SURENDER KUMAR CHAWLA,DEHRADUN vs. ACIT, CC, DEHRADUN, HALDWANI

In the result, assessee’s appeals; ITA No

Bench: BEFORESHRI CHALLA NAGENDRA PRASAD (Judicial Member), SHRI AVDHESH KUMAR MISHRA (Accountant Member)

71,000/- on account of alleged purchase of property from Mr. Mohan Pal as alleged unexplained investment u/s 69 of the Income Tax Act, 1961. 7. The learned assessing officer as also learned CIT(A) have erred in making and confirming addition of Rs.2,94,00,000/- on account of alleged purchase of property from Mr. Mohan Pal as alleged

SH. SURENDER KUMAR CHAWLA,RUDRAPUR vs. ACIT, CC- HALDWANI, HALDWANI

In the result, assessee's appeals; ITA No

71,000/- on account of alleged purchase of property from Mr. Mohan Pal as alleged unexplained investment u/s 69 of the Income Tax Act, 1961. 7. The learned assessing officer as also learned CIT(A) have erred in making and confirming addition of Rs.2,94,00,000/- on account of alleged purchase of property from Mr. Mohan Pal as alleged

SH. SURINDER KUMAR CHAWLA,RUDRAPUR vs. ACIT,CC, HALDWANI, HALDWANI

In the result, assessee’s appeals; ITA No

Bench: BEFORESHRI CHALLA NAGENDRA PRASAD (Judicial Member), SHRI AVDHESH KUMAR MISHRA (Accountant Member)

71,000/- on account of alleged purchase of property from Mr. Mohan Pal as alleged unexplained investment u/s 69 of the Income Tax Act, 1961. 7. The learned assessing officer as also learned CIT(A) have erred in making and confirming addition of Rs.2,94,00,000/- on account of alleged purchase of property from Mr. Mohan Pal as alleged

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.,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

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