ACIT, MEERUT vs. SHRI SACHIN UPADHAYA, DEHRADUN

In the result, the appeal is dismissed

Bench: Shri Saktijit Dey & Dr. B.R.R. Kumarassessment Year: 2007-08

section 68 of the act. 8.2 Before the first appellate authority, the assessee furnished date wise details of the transaction and submitted that substantial sum of money was withdrawn in cash from his bank account. Further explaining, the assessee submitted that the cash was withdrawn as the assessee was in the process of buying

METRO FROZEN FRUIT & VEGETABLES PVT. LTD.,ROORKEE vs. DCIT, CIRCLE, HARIDWAR

In the result, the appeal of the assessee is party allowed

Bench: Shri R.K. Panda & Shri N. K. Choudhry[Assessment Year: 2009-10] Metro Frozen Fruits & Dcit, Vegetables Pvt. Ltd. Circle Haridwar, Plot No.22, Rajpur, Vs Uttarakhan Bhagwanpur, Roorkee, Uttrakhand Pan-Aaecm4521F Assessee Revenue Assessee By Sh. Piyush Kuchhal, Fca Revenue By Ms. Poonam Sharma Cit-Dr Date Of Hearing 23.02.2022 Date Of Pronouncement 08.03.2022 Order Per R.K. Panda, Am, This Appeal Filed By The Assessee Is Directed Against The Order Dated 24.01.2019 Of The Learned Cit(A), Dehradun, Relating To Assessment Year 2009-10. 2. The Grounds Raised By The Assessee Are As Under:-

68,863/- 57,69,771/- 27,76,846/ 3,15,73,341/- 30,25,318/- 2,85,48,023/- 6 A.Y. 2009-10 Particulars Rate Addition Deduction Total WDV as on Dep for the WDV as on 01.04.2008 Year 31.03.2009 More than Less than 180 Days 180 Days Computer

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

73,00,000/- and Rs. 40,95,000/- without appreciating that in view of the amended provisions, the burden u/s 68 could not have been said to be discharged by assessee just by filing confirmations/financial statement for the first time at appellate stage in view of the ratio of decision in case of NR Portfolio Pvt. Ltd.264 CTR 258(Delhi

KUNWAR TOSEEN,KOTDWAR DISTT. PAURI GARHWAL vs. INCOME TAX OFFICER, KOTDWAR

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

Bench: Shri Vimal Kumar & Shri Brajesh Kumar Singh

73,750/- in one or more accounts of cash deposits and assessee did not file return of income. After recording reasons, the case was reopened by issue of notice under Section 148 of the Act on 25.03.2023 with prior approval of the DCIT, Dehradun. Despite intimation letter dated 17.08.2022, multiple notices under Sections 142(1) dated

KUNWAR TOSEEN,KOTDWAR DISTT. PAURI GARHWAL vs. INCOME TAX OFFICER , KOTDWAR

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

Bench: Shri Vimal Kumar & Shri Brajesh Kumar Singh

73,750/- in one or more accounts of cash deposits and assessee did not file return of income. After recording reasons, the case was reopened by issue of notice under Section 148 of the Act on 25.03.2023 with prior approval of the DCIT, Dehradun. Despite intimation letter dated 17.08.2022, multiple notices under Sections 142(1) dated

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

73,48,726/- in respect of intra group services. Accordingly, the AO, in the draft assessment order passed on 19th March, 2021, made addition of the same. The AO, in the draft assessment order also made an addition of Rs.8,65,98,743/- on account of expenses pertaining to Branch office, addition of Rs.25,28,05,028/- on account

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

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

RAJKAMAL AGNIHOTRI,DEHRADUN vs. INCOME TAX OFFICER , DEHRADUN

In the result, the appeal of the assessee is allowed

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2022-23] Rajkamal Agnihotri Vs Ito Shivalik View, Lane No.3, Ward-1(1)(3) Jogiala, Ring Road, Dehradun Nathanpur, Dehradun Uttarakhand Uttarakhand -248005 Pan-Amqpa2608G Appellant Respondent Appellant By Shri K. K. Juneja, Adv. Respondent By Ms. Poonam Sharma, Cit Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 06.11.2025 By Ld. Commissioner Of Income Tax (A), Nfac, Delhi [“Ld. Cit(A)”] In Appeal No. Nfac/2021-22/10408670 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 14.03.2024 Passed U/S 143(3) R.W.S. 144B Of The Act Pertaining To Assessment Year 2022-23. 2. Brief Facts Of The Case Are That Assessee Is An Individual & Filed His Return Of Income On 28.07.2022, Declaring Total Income Of Inr 4,89,260/-. The Return Was Updated On 11.09.2023 U/S 139(8A) Of The Act, Declaring Total Income Of Inr 73,92,200/- & Paid The Taxes Alongwith The Interest Thereon. The Case Of The Assessee Was Selected For Scrutiny On The Ground That No Capital Gain Was Reported In Itr Though The Assessee Has Sold The Property Thereafter, The Assessment Was Completed U/S 143(3)/144B Of The Act Dated 14.03.2024 Wherein Income Declared In The Updated Return Filed U/S 139(8A) Of The Act Was Accepted However, Penalty Proceedings U/S 270A(1) R.W.S. 270A(8) & 270A(9)(A) Of The Act Were Initiated. The Ao Thereafter, Proceeded With Pending Penalty Proceedings & Imposed The Penalty In Terms Of The Order Dated 14.03.2024 Imposing The Penalty Of Inr 31,58,542/- U/S 270A Of The Act.

73,92,200/- and paid the taxes alongwith the interest thereon. The case of the assessee was selected for scrutiny on the ground that no capital gain was reported in ITR though the assessee has sold the property thereafter, the assessment was completed u/s 143(3)/144B of the Act dated 14.03.2024 wherein income declared in the updated return filed

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

73 in case of the assessee dated 1 August 2012 wherein it has been held that amount received by the assessee for providing Mud engineering services to an Indian company in connection with the extraction of mineral oils has to be taxed as fees for technical services. He referred to paragraph number [3] where the assessee itself has stated before

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

73 in case of the assessee dated 1 August 2012 wherein it has been held that amount received by the assessee for providing Mud engineering services to an Indian company in connection with the extraction of mineral oils has to be taxed as fees for technical services. He referred to paragraph number [3] where the assessee itself has stated before

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

73 in case of the assessee dated 1 August 2012 wherein it has been held that amount received by the assessee for providing Mud engineering services to an Indian company in connection with the extraction of mineral oils has to be taxed as fees for technical services. He referred to paragraph number [3] where the assessee itself has stated before

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

73 in case of the assessee dated 1 August 2012 wherein it has been held that amount received by the assessee for providing Mud engineering services to an Indian company in connection with the extraction of mineral oils has to be taxed as fees for technical services. He referred to paragraph number [3] where the assessee itself has stated before

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

73 in case of the assessee dated 1 August 2012 wherein it has been held that amount received by the assessee for providing Mud engineering services to an Indian company in connection with the extraction of mineral oils has to be taxed as fees for technical services. He referred to paragraph number [3] where the assessee itself has stated before

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

73 in case of the assessee dated 1 August 2012 wherein it has been held that amount received by the assessee for providing Mud engineering services to an Indian company in connection with the extraction of mineral oils has to be taxed as fees for technical services. He referred to paragraph number [3] where the assessee itself has stated before

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

73 in case of the assessee dated 1 August 2012 wherein it has been held that amount received by the assessee for providing Mud engineering services to an Indian company in connection with the extraction of mineral oils has to be taxed as fees for technical services. He referred to paragraph number [3] where the assessee itself has stated before

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

73,02,820/-. The assessee in its return of income admitted that there is a Permanent Establishment (PE) in India. The ld. AO observed that for availing the benefit of provisions of sectin 44BB of the Act, it is essential that assessee should have a PE in India ITA No. 6126/Del/2017 & ITA No. 5223/Del/2018 (Assessee) ITA No. 6173/Del/2017