DCIT, CENTRAL CIRCLE, DEHRADUN vs. GOLDEN MANOR, DEHRADUN

Appeals of the Revenue are dismissed

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.103 &104/देहरादून/2019(िन.व. 2015-16 & 2016-17)

68,97,657/- from the business of Real Estate for AY 2015-16 and Rs.2,92,02,474/- for AY 2016-17. The assessee being in the business of Real Estate Development was required to adopt Percentage Completion Method as per Accounting Standard-7 (AS-7). The Assessing Officer (AO) computed the gross profit as per norms laid down

PUSHPA DEVI,RISHIKESH vs. INCOME TAX OFFICER, RISHIKESH

In the result the Appeal of the Assessee is allowed

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Pushpa Devi Vs. Income Tax Officer, 31-Awas Vikas Colony, Ward 1(4) (1), Verbhadara Road, Rishikesh, Rishikesh, 249201, Uttarakhand Rishikesh, Uttarakhand Pan: Aldpd9616P Appellant Respondent Assessee By Sh. K. K. Juneja, Adv Revenue By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 10/07/2025 Date Of Pronouncement 08/08/2025 Order

Section 144B of the Income Tax Act, 1961 ('Act' for short) by making an addition of Rs. 36,05,530/- on account of suppression of sale receipts u/s 28 of the Act and also made addition of Rs. 13,74,000/- u/s 68 of the Act on account of unsecured loan. Aggrieved by the assessment order dated 05/03/2024

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.

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

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

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

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