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 that the functional profile of the Appellants PE is even below a low risk distributor and that the Appellants PE does not assume title of the goods sold in India and merely provides low end coordination support services

WEATHERFORD OIL TOOLS M E LTD.,DEHRADUN vs. DCIT, CIRCLE- 2, INTL. 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 that the functional profile of the Appellants PE is even below a low risk distributor and that the Appellants PE does not assume title of the goods sold in India and merely provides low end coordination support services

ACIT, CIRCLE- II, INTERNATIONAL TAXATION, DEHRADUN vs. WEATHERFORD OIL TOOLS M.E. LTD., 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 that the functional profile of the Appellants PE is even below a low risk distributor and that the Appellants PE does not assume title of the goods sold in India and merely provides low end coordination support services

WEATHERFORD OIL TOOLS ME LTD.,DEHRADUN vs. ACIT, CIRCLE- II, 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 that the functional profile of the Appellants PE is even below a low risk distributor and that the Appellants PE does not assume title of the goods sold in India and merely provides low end coordination support services

ACIT, CIRCLE- II, INTERNATIONAL TAXATION , DEHRADUN vs. WEATHERFORD OIL TOOLS M.E. LTD., 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 that the functional profile of the Appellants PE is even below a low risk distributor and that the Appellants PE does not assume title of the goods sold in India and merely provides low end coordination support services

ACIT, CIRCLE- II, INTERNATIONAL TAXATION, DEHRADUN vs. WEATHERFORD OIL TOOLS ME LTD., 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 that the functional profile of the Appellants PE is even below a low risk distributor and that the Appellants PE does not assume title of the goods sold in India and merely provides low end coordination support services

RUKMAN AGARWAL,U S NAGAR vs. ACIT, CENTRAL CIRCLE, HALDWANI

In the result the appeals filed by the assessee are allowed

Bench: Shri Amit Shukla & Shri B.R.R. Kumarassessment Year: 2010-11

44,00,000/- Siddheshwari Vyapaar Pvt. 'Ltd, 18.10.2011 RTGS-ORBCH 11291064949 20,00,000/- 18.10.2011 RTGS-ORBCH 11291070149 15,00,000/- 3. The Ld. AO thus observed that in these bank statements, huge amount aggregating to Rs. 2,00,00,000/- in each of the assessees have been received either from M/s. Sunview Retail Pvt. Ltd. or M/s. Siddheswari Vyapaar

SHIV KUMAR AGARWAL,U S NAGAR vs. ACIT, CENTRAL CIRCLE, HALDWANI

In the result the appeals filed by the assessee are allowed

Bench: Shri Amit Shukla & Shri B.R.R. Kumarassessment Year: 2010-11

44,00,000/- Siddheshwari Vyapaar Pvt. 'Ltd, 18.10.2011 RTGS-ORBCH 11291064949 20,00,000/- 18.10.2011 RTGS-ORBCH 11291070149 15,00,000/- 3. The Ld. AO thus observed that in these bank statements, huge amount aggregating to Rs. 2,00,00,000/- in each of the assessees have been received either from M/s. Sunview Retail Pvt. Ltd. or M/s. Siddheswari Vyapaar

SAURABH AGARWAL,U S NAGAR vs. ACIT, CENTRAL CIRCLE, HALDWANI

In the result the appeals filed by the assessee are allowed

Bench: Shri Amit Shukla & Shri B.R.R. Kumarassessment Year: 2010-11

44,00,000/- Siddheshwari Vyapaar Pvt. 'Ltd, 18.10.2011 RTGS-ORBCH 11291064949 20,00,000/- 18.10.2011 RTGS-ORBCH 11291070149 15,00,000/- 3. The Ld. AO thus observed that in these bank statements, huge amount aggregating to Rs. 2,00,00,000/- in each of the assessees have been received either from M/s. Sunview Retail Pvt. Ltd. or M/s. Siddheswari Vyapaar

ABHISHEK AGARWAL,U S NAGAR vs. ACIT, CENTRAL CIRCLE, HALDWANI

In the result the appeals filed by the assessee are allowed

Bench: Shri Amit Shukla & Shri B.R.R. Kumarassessment Year: 2010-11

44,00,000/- Siddheshwari Vyapaar Pvt. 'Ltd, 18.10.2011 RTGS-ORBCH 11291064949 20,00,000/- 18.10.2011 RTGS-ORBCH 11291070149 15,00,000/- 3. The Ld. AO thus observed that in these bank statements, huge amount aggregating to Rs. 2,00,00,000/- in each of the assessees have been received either from M/s. Sunview Retail Pvt. Ltd. or M/s. Siddheswari Vyapaar