B G EXPLORATION & PRODUCTION INDIA LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME, DDIT/ ADIT (INTERNATIONAL TAXATION), CIRCLE-1, DEHRADUN, DEHRADUN, UTTARAKHAND

In the result, both the appeals of the assessee are allowed

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

Transfer Pricing Officer, but it is beyond his authority to question the wisdom of Assessee. It is not the prerogative of revenue to direct Assessee to conduct its business in a particular manner. It is also not proper to ask and Assessee to conduct its business in a manner which is understood by the revenue, despite heavy business risk

B G EXPLORATION & PRODUCTION INDIA LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME, DDIT/ ADIT (INTERNATIONAL TAXATION), CIRCLE-1, DEHRADUN, DEHRADUN

In the result, both the appeals of the assessee are allowed

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

Transfer Pricing Officer, but it is beyond his authority to question the wisdom of Assessee. It is not the prerogative of revenue to direct Assessee to conduct its business in a particular manner. It is also not proper to ask and Assessee to conduct its business in a manner which is understood by the revenue, despite heavy business risk

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)

1), involving proceedings ITA Nos.107 & 105/DDN/2024 under sections 143(3) r.w.s. 254 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’), respectively. Heard both the parties. Case file perused. 2. It transpires during the course of hearing that there arises the first and foremost legal issue of validity of the learned CIT(A)’s identical impugned lower

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

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

1), involving proceedings ITA Nos.107 & 105/DDN/2024 under sections 143(3) r.w.s. 254 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’), respectively. Heard both the parties. Case file perused. 2. It transpires during the course of hearing that there arises the first and foremost legal issue of validity of the learned CIT(A)’s identical impugned lower