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

9(l)(vii) read with Section 44DA of the Act and are eligible for treatment u/s 44BB of the Act, not appreciating the findings of the AO that the supply of the material is intrinsically linked with the performance of mud engineering services under composite contracts with the recipients of services. 2. Whether on the facts and circumstances

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

9(l)(vii) read with Section 44DA of the Act and are eligible for treatment u/s 44BB of the Act, not appreciating the findings of the AO that the supply of the material is intrinsically linked with the performance of mud engineering services under composite contracts with the recipients of services. 2. Whether on the facts and circumstances

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

9(l)(vii) read with Section 44DA of the Act and are eligible for treatment u/s 44BB of the Act, not appreciating the findings of the AO that the supply of the material is intrinsically linked with the performance of mud engineering services under composite contracts with the recipients of services. 2. Whether on the facts and circumstances

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

9(l)(vii) read with Section 44DA of the Act and are eligible for treatment u/s 44BB of the Act, not appreciating the findings of the AO that the supply of the material is intrinsically linked with the performance of mud engineering services under composite contracts with the recipients of services. 2. Whether on the facts and circumstances

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

9(l)(vii) read with Section 44DA of the Act and are eligible for treatment u/s 44BB of the Act, not appreciating the findings of the AO that the supply of the material is intrinsically linked with the performance of mud engineering services under composite contracts with the recipients of services. 2. Whether on the facts and circumstances

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

9(l)(vii) read with Section 44DA of the Act and are eligible for treatment u/s 44BB of the Act, not appreciating the findings of the AO that the supply of the material is intrinsically linked with the performance of mud engineering services under composite contracts with the recipients of services. 2. Whether on the facts and circumstances

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

9(l)(vii) read with Section 44DA of the Act and are eligible for treatment u/s 44BB of the Act, not appreciating the findings of the AO that the supply of the material is intrinsically linked with the performance of mud engineering services under composite contracts with the recipients of services. 2. Whether on the facts and circumstances

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

9(1)(vii) of the Act and therefore taxable under section 44BB of the Act:  Corpro Systems Limited, UK, In re [(2016) 389 ITR 0029];  Addl. DIT (International Taxation) vs Halliburtan Offshore Services Inc. [(2016) 47 CCH 0425] (Delhi ITAT);  ITO (International Taxation) vs. ONGC [(2016) ITA No. 1596, 1597, 1598 & 1599/Del/2012] (Delhi ITAT);  National Oil Well Maintenance Company

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

9(1)(vii) of the Act and therefore taxable under section 44BB of the Act:  Corpro Systems Limited, UK, In re [(2016) 389 ITR 0029];  Addl. DIT (International Taxation) vs Halliburtan Offshore Services Inc. [(2016) 47 CCH 0425] (Delhi ITAT);  ITO (International Taxation) vs. ONGC [(2016) ITA No. 1596, 1597, 1598 & 1599/Del/2012] (Delhi ITAT);  National Oil Well Maintenance Company

DCIT, CIRCLE- 2, DEHRADUN vs. V K AGARWAL & CO., NEW DELHI

In the result, the appeal of the Revenue is dismissed

Bench: The Ao During The Course Of Assessment Proceedings. 2. The Ld. Cit(A) Has Erred In Law & On Facts In Deleting The Addition Of Rs.34,00,000/- Made On Account Of Unsecured Loan U/S 68 Of The I.T. Act, 1961 As The Assessee Could Not Furnish/Produce The Confirmation Of Unsecured Loan From M/S Tirupati Investment. 3. The Order Of The Ld. Cit(A) Be Set-A-Side & The Order Of The Ao Be Restored.

section 68 of the Act by proving the three necessary ingredients thereon. Hence, we do not find any infirmity in the order of learned CIT(A) in granting relief to the assessee in this regard. Accordingly, the grounds raised by the Revenue are dismissed. 9

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

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

WEATHERFORD OIL TOOLS M E LTD.,DEHRADUN vs. DCIT, CIRCLE- 2, INTL. 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 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 ME LTD.,DEHRADUN vs. ACIT, CIRCLE- II, 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 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

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.

9 of section 270A the same is initiated. He placed reliance on the judgement of Co-ordinate Bench of Delhi Tribunal in the case of Greenwoods Govt. Officers Welfare Society in ITA No.609/Del/2023 wherein vide order dated 26.10.2023 it is held that if the income is declared in the revised return and additional tax alongwith interest is paid 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

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. 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

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

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. 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