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]

Pricing Officer (TPO), the time) limit available stands extended by another 12 months, and in the present case, the upper time limit for completion of assessment proceedings would expire on 30.09.2021. 18. In the present case, the final assessment order passed by the A.O. under Section 143(3) r.w.s. 144C(13) r.w.s. 144B dated 28.07.2022 is clearly beyond the limitation

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]

Pricing Officer (TPO), the time) limit available stands extended by another 12 months, and in the present case, the upper time limit for completion of assessment proceedings would expire on 30.09.2021. 18. In the present case, the final assessment order passed by the A.O. under Section 143(3) r.w.s. 144C(13) r.w.s. 144B dated 28.07.2022 is clearly beyond the limitation

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]

Pricing Officer (TPO), the time) limit available stands extended by another 12 months, and in the present case, the upper time limit for completion of assessment proceedings would expire on 30.09.2021. 18. In the present case, the final assessment order passed by the A.O. under Section 143(3) r.w.s. 144C(13) r.w.s. 144B dated 28.07.2022 is clearly beyond the limitation

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]

Pricing Officer (TPO), the time) limit available stands extended by another 12 months, and in the present case, the upper time limit for completion of assessment proceedings would expire on 30.09.2021. 18. In the present case, the final assessment order passed by the A.O. under Section 143(3) r.w.s. 144C(13) r.w.s. 144B dated 28.07.2022 is clearly beyond the limitation

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]

Pricing Officer (TPO), the time) limit available stands extended by another 12 months, and in the present case, the upper time limit for completion of assessment proceedings would expire on 30.09.2021. 18. In the present case, the final assessment order passed by the A.O. under Section 143(3) r.w.s. 144C(13) r.w.s. 144B dated 28.07.2022 is clearly beyond the limitation

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]

Pricing Officer (TPO), the time) limit available stands extended by another 12 months, and in the present case, the upper time limit for completion of assessment proceedings would expire on 30.09.2021. 18. In the present case, the final assessment order passed by the A.O. under Section 143(3) r.w.s. 144C(13) r.w.s. 144B dated 28.07.2022 is clearly beyond the limitation

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]

Pricing Officer (TPO), the time) limit available stands extended by another 12 months, and in the present case, the upper time limit for completion of assessment proceedings would expire on 30.09.2021. 18. In the present case, the final assessment order passed by the A.O. under Section 143(3) r.w.s. 144C(13) r.w.s. 144B dated 28.07.2022 is clearly beyond the limitation

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]

Pricing Officer (TPO), the time) limit available stands extended by another 12 months, and in the present case, the upper time limit for completion of assessment proceedings would expire on 30.09.2021. 18. In the present case, the final assessment order passed by the A.O. under Section 143(3) r.w.s. 144C(13) r.w.s. 144B dated 28.07.2022 is clearly beyond the limitation

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 No. 1 is in favour of appellant, whether the notional tax reimbursement in the case of Unit VII of Thermal Power Station II whose entire income is deductible u/s 80IA should also be taken into account for computing

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 No. 1 is in favour of appellant, whether the notional tax reimbursement in the case of Unit VII of Thermal Power Station II whose entire income is deductible u/s 80IA should also be taken into account for computing

ACIT, CIRCLE- II, INTERNATIONAL TAXATION, DEHRADUN vs. WEATHERFORD OIL TOOLS ME LTD., DEHRADUN

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

d ACIT CIT(A)-2, Noida, 143(3)/144C A.Y. 2015-16 Oil Tools ME Appeal No. 93/CIT(A)- (3)(b) Ltd. 2/2017-18/ Noida Dated 22.06.2018 4. 7477/Del/2017 ACIT Weatherford CIT(A)-2, Noida, 143(3)/144C Oil Tools ME A.Y. 2013-14 Appeal No. 45/CIT(A)- (3)(b) Ltd. 2 /2016-17 Dated 27.09.2017 5. 417/Del/2018 ACIT Weatherford

ACIT, CIRCLE- II, INTERNATIONAL TAXATION, DEHRADUN vs. WEATHERFORD OIL TOOLS M.E. LTD., DEHRADUN

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

d ACIT CIT(A)-2, Noida, 143(3)/144C A.Y. 2015-16 Oil Tools ME Appeal No. 93/CIT(A)- (3)(b) Ltd. 2/2017-18/ Noida Dated 22.06.2018 4. 7477/Del/2017 ACIT Weatherford CIT(A)-2, Noida, 143(3)/144C Oil Tools ME A.Y. 2013-14 Appeal No. 45/CIT(A)- (3)(b) Ltd. 2 /2016-17 Dated 27.09.2017 5. 417/Del/2018 ACIT Weatherford

WEATHERFORD OIL TOOLS ME LTD.,DEHRADUN vs. ACIT, CIRCLE- II, INTERNATIONAL TAXATION, DEHRADUN

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

d ACIT CIT(A)-2, Noida, 143(3)/144C A.Y. 2015-16 Oil Tools ME Appeal No. 93/CIT(A)- (3)(b) Ltd. 2/2017-18/ Noida Dated 22.06.2018 4. 7477/Del/2017 ACIT Weatherford CIT(A)-2, Noida, 143(3)/144C Oil Tools ME A.Y. 2013-14 Appeal No. 45/CIT(A)- (3)(b) Ltd. 2 /2016-17 Dated 27.09.2017 5. 417/Del/2018 ACIT Weatherford

ACIT, CIRCLE- II, INTERNATIONAL TAXATION , DEHRADUN vs. WEATHERFORD OIL TOOLS M.E. LTD., DEHRADUN

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

d ACIT CIT(A)-2, Noida, 143(3)/144C A.Y. 2015-16 Oil Tools ME Appeal No. 93/CIT(A)- (3)(b) Ltd. 2/2017-18/ Noida Dated 22.06.2018 4. 7477/Del/2017 ACIT Weatherford CIT(A)-2, Noida, 143(3)/144C Oil Tools ME A.Y. 2013-14 Appeal No. 45/CIT(A)- (3)(b) Ltd. 2 /2016-17 Dated 27.09.2017 5. 417/Del/2018 ACIT Weatherford

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

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

d ACIT CIT(A)-2, Noida, 143(3)/144C A.Y. 2015-16 Oil Tools ME Appeal No. 93/CIT(A)- (3)(b) Ltd. 2/2017-18/ Noida Dated 22.06.2018 4. 7477/Del/2017 ACIT Weatherford CIT(A)-2, Noida, 143(3)/144C Oil Tools ME A.Y. 2013-14 Appeal No. 45/CIT(A)- (3)(b) Ltd. 2 /2016-17 Dated 27.09.2017 5. 417/Del/2018 ACIT Weatherford

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

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

d ACIT CIT(A)-2, Noida, 143(3)/144C A.Y. 2015-16 Oil Tools ME Appeal No. 93/CIT(A)- (3)(b) Ltd. 2/2017-18/ Noida Dated 22.06.2018 4. 7477/Del/2017 ACIT Weatherford CIT(A)-2, Noida, 143(3)/144C Oil Tools ME A.Y. 2013-14 Appeal No. 45/CIT(A)- (3)(b) Ltd. 2 /2016-17 Dated 27.09.2017 5. 417/Del/2018 ACIT Weatherford

SH. DEVENDRA DUTT PANT,HARIDWAR vs. DCIT , UTTARKAHAND

Appeal is partly allowed in above terms

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

d) "The determination of the character of land, according to the purpose for which it is meant or set apart and can be used, is a matter which ought to be determined on the facts of each particular case", (e) The fact that the land is assessed to the Land Revenue as agricultural land under the State Revenue