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

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.,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

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

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 (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

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

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

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)

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, 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

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

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

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

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

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