DCIT, CIRCLE- I, INTERNATIONAL TAXATION, DEHRADUN vs. EXPRESS DRILLING SYSTEMS LLC, DEHRADUN

In the result, cross objection filed by the assessee is partly

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshआ.अ.सं/.I.T.A No.6114/Del/2017 िनधा"रणवष"/Assessment Year: 2009-10 बनाम Dcit, Express Drilling Circle-1, Vs. Systems Llc, International Taxation, C/O Nangia & Co., 1St Floor, Ida, 46, Dehradun, Uttarakhand. E.C. Road, Dehradun, Uttarakhand. Pan No.Aabce6891R अपीलाथ" Appellant ""यथ"/Respondent & Cross Objection No. 13/Del/2018 (In I.T.A No.6114/Del/2017) िनधा"रणवष"/Assessment Year: 2009-10 बनाम Express Drilling Systems Llc, Dcit, Vs. C/O Nangia & Co., Circle-1, 1St Floor, Ida, 46, International Taxation, E.C. Road, Dehradun, Dehradun, Uttarakhand. Uttarakhand. Pan No. Aabce6891R अपीलाथ" Appellant ""यथ"/Respondent

Transfer Pricing Officer (TPO) in relation to the international transaction between the respondent- assessee and its Associated Enterprise (AE). Draft

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

Transfer Pricing Officer ("TPO") / AO / DRP grossly erred in law and on facts by making an upward transfer pricing adjustment

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

Transfer Pricing Officer ("TPO") / AO / DRP grossly erred in law and on facts by making an upward transfer pricing adjustment

KARAM SAFETY PRIVATE LIMITED,UDHAM SINGH NAGAR vs. THE INCOME TAX OFFICER, WARD-2(3)(5), UDHAM SINGH NAGAR

In the result, both the appeals of the assessee are allowed and that of the Stay Applications are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer 3(2)(2) (“TPO”) for determination of arm’s length price of the specified domestic transactions (“SDT”) / international

KARAM SAFETY PRIVATE LIMITED,SITARGANJ vs. THE INCOME TAX OFFICER, WARD-2(3)(5), UDHAM SINGH NAGAR

In the result, both the appeals of the assessee are allowed and that of the Stay Applications are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer 3(2)(2) (“TPO”) for determination of arm’s length price of the specified domestic transactions (“SDT”) / international

SIME DARBY ENGINEERING SDN BHD,GURGAON vs. DCIT (INTERNATIONAL TAXATION), CIRCLE-2, DEHRADUN

In the result, appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Transfer Pricing Officer (TPO), the time) limit available stands extended by another 12 months, and in the present case, the upper

NATIONAL OILWELL VARCO PTE. LTD.,MUMBAI vs. DCIT (INTERNATIONAL TAXATION), CI9RCLE-2, DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Transfer Pricing Officer (TPO), the time) limit available stands extended by another 12 months, and in the present case, the upper

NATIONAL OILWELL VARCO PTE. LTD.,MUMBAI vs. DCIT (INTERNATIONAL TAXATION), DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Transfer Pricing Officer (TPO), the time) limit available stands extended by another 12 months, and in the present case, the upper

NATIONAL OILWELL VARCO PTE LTD.,MUMBAI vs. DCIT (INTERNATIONAL TAXATION), DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Transfer Pricing Officer (TPO), the time) limit available stands extended by another 12 months, and in the present case, the upper

SIME DARBY ENGINEERING SDN BHD,DELHI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRCLE-1, DEHRADUN

In the result, appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Transfer Pricing Officer (TPO), the time) limit available stands extended by another 12 months, and in the present case, the upper

NATIONAL OIL WELL VARCO PTE. LTD (FORMERLY KNOWN AS VARCO INTERNATIONAL PTE. LTD),MAHARASHTRA vs. THE DEPUTY DIRECTOR OF INCOME TAX CIRCLE-1( INTERNATIONAL TAXATION ), DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Transfer Pricing Officer (TPO), the time) limit available stands extended by another 12 months, and in the present case, the upper

SIME DARBY ENGINEERING SDNBHD,MALAYSIA vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION ) CIRCLE-1, DEHRADUN

In the result, appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Transfer Pricing Officer (TPO), the time) limit available stands extended by another 12 months, and in the present case, the upper

NATIONAL OILWELL VARCO PTE. LTD. (FORMERLY KNOWN AS VARCO INTERNATIONAL PTE LTD.),MUMBAI vs. DCIT (INTERNATIONAL TAXATION), CIRCLE-2, DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Transfer Pricing Officer (TPO), the time) limit available stands extended by another 12 months, and in the present case, the upper

M/S. THDC INDIA LIMITED,RISHIKESH vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2017-18] M/S. Thdc India Ltd. Vs Pcit Ganga Bhawan, Aaykar Bhawan, Pragatipuram, Bye Pass 13 A, Subhash Road, Road, Rishikesh, Uttarakhand Uttarakhand-249201 Pan-Aaact7905Q Appellant Respondent Assessee By Shri Jeetan Nagpal, Ca Shri Sanjay Arora, Ca & Ms. Pallavi, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 18.02.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 27.03.2022 By Ld. Pr. Commissioner Of Income Tax, Dehradun [“Ld. Pcit”] Passed U/S 263 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 30.12.2019 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is A Joint Venture Company Of Government Of India & Government Of Uttar Pradesh & Engaged In The Business Of Generation & Supply Of Hydro- Electric As Well As Wind Power & Also Engaged In Construction Of Hydro Power Plants. The Return Of Income Was Filed On 30.10.2017, Declaring Total Income Of Inr 6,84,04,420/- After Claiming Deduction U/S 80-Ia Of The Act Of Inr 948,40,76,282/-. The Book Profits Was Shown At Inr 7,84,96,09,382/- & Mat Of Inr 1,67,52,32,236/- Was Paid. The Case Of The Assessee Was Selected For Scrutiny & After Considering The Submissions Made, Total Income Was Assessed At Inr 4,63,78,80,698/- By Making Disallowance Out Of Deduction Claimed U/S 80-Ia Of The Act To The Extent Of Inr 211,15,54,378/- & Further Making Addition Of Inr 245,79,21,900/- On Account Of Late Payment Surcharge On Outstanding Debtors For The Period Of 10 Months Holding The Same As Taxable On Accrual Basis & No Deduction U/S 80Ia Was Allowed On Such Addition.

transfer price of lignite and sale price of electricity in computing relief under Section 801A/80IB? 2. If the answer to the question

M/S. UJVN LIMITED,DEHRADUN vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, DEHRADUN

In the result, the appeal of the Assessee is allowed

Bench: Sh. C. N. Prasad & Shri M. Balaganesh(Through Video Conferencing) M/S. Ujvn Limited, Vs. The Principal Commissioner C/O. Mn/S. Rra Taxindia, Of Income, D-28, South Extension, Aayakar Bhawan, 13A, Part-I, Subhash Road, Dehradun New Delhi (Appellant) (Respondent) Pan: Aaacu6672R Assessee By : Dr. Rakesh Gupta, Adv Shri Somil Aggarwal, Adv Revenue By: Shri N. S. Jangpangi, Cit Dr Date Of Hearing 24/08/2023 Date Of Pronouncement 15/09/2023

transfer price of lignite and sale price of electricity in computing relief under Section 801A/80IB? 2. If the answer to the question

DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, DEHRADUN vs. BG EXPLORATION PRODUCDTION INDIA LIMITED, MUMBAI

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal(Through Video Conferencing)

Transfer Pricing Officer “TPO” in light of the fact that it had declared its international transaction with related parties in both

DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, DEHRADUN vs. BG EXPLORATION, MUMBAI

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal(Through Video Conferencing)

Transfer Pricing Officer “TPO” in light of the fact that it had declared its international transaction with related parties in both

WEATHERFORD OIL TOOLS M.E. LTD.,NOIDA vs. DCIT, CIRCLE- 2, INTERNATIONAL TAXATION, DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

transfer pricing regulations. Ground No. 4 That Ld CIT(A) erred in law and on facts by failing to appreciate