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

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 adjustment of Rs.2,28,48,22,523 in total towards international transactions pertaining to payment of management service and unit charges, IM charges and payroll expenses to its AE. Ground No. 2: Erroneous rejection of Transactional Net Margin Method ("TNMM”) and selection of Comparable Uncontrolled Price ("CUP”) Method 2.1. The learned TPO / AO / DRP / have erred

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

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

46, EC Road Circle-2, Dehradun-248001 (APPELLANT) (RESPONDENT) PAN No. AAACW1524G Assessee by: Sh. Salil Kapoor, Sh. Anil Chachra, Ms. Ananya Kapoor & Sh. S. L. Chandani, Advs. Revenue by: Sh. Mithun Shete, Sr. DR Date of Hearing: 19.03.2025 Date of Pronouncement: 28.04.2025 ORDER Per Bench: These assessee’s and Revenue’s three cross appeals each involve the following relevant

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

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

46, EC Road Circle-2, Dehradun-248001 (APPELLANT) (RESPONDENT) PAN No. AAACW1524G Assessee by: Sh. Salil Kapoor, Sh. Anil Chachra, Ms. Ananya Kapoor & Sh. S. L. Chandani, Advs. Revenue by: Sh. Mithun Shete, Sr. DR Date of Hearing: 19.03.2025 Date of Pronouncement: 28.04.2025 ORDER Per Bench: These assessee’s and Revenue’s three cross appeals each involve the following relevant

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

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

46, EC Road Circle-2, Dehradun-248001 (APPELLANT) (RESPONDENT) PAN No. AAACW1524G Assessee by: Sh. Salil Kapoor, Sh. Anil Chachra, Ms. Ananya Kapoor & Sh. S. L. Chandani, Advs. Revenue by: Sh. Mithun Shete, Sr. DR Date of Hearing: 19.03.2025 Date of Pronouncement: 28.04.2025 ORDER Per Bench: These assessee’s and Revenue’s three cross appeals each involve the following relevant

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

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

46, EC Road Circle-2, Dehradun-248001 (APPELLANT) (RESPONDENT) PAN No. AAACW1524G Assessee by: Sh. Salil Kapoor, Sh. Anil Chachra, Ms. Ananya Kapoor & Sh. S. L. Chandani, Advs. Revenue by: Sh. Mithun Shete, Sr. DR Date of Hearing: 19.03.2025 Date of Pronouncement: 28.04.2025 ORDER Per Bench: These assessee’s and Revenue’s three cross appeals each involve the following relevant

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

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

46, EC Road Circle-2, Dehradun-248001 (APPELLANT) (RESPONDENT) PAN No. AAACW1524G Assessee by: Sh. Salil Kapoor, Sh. Anil Chachra, Ms. Ananya Kapoor & Sh. S. L. Chandani, Advs. Revenue by: Sh. Mithun Shete, Sr. DR Date of Hearing: 19.03.2025 Date of Pronouncement: 28.04.2025 ORDER Per Bench: These assessee’s and Revenue’s three cross appeals each involve the following relevant

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

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

46, EC Road Circle-2, Dehradun-248001 (APPELLANT) (RESPONDENT) PAN No. AAACW1524G Assessee by: Sh. Salil Kapoor, Sh. Anil Chachra, Ms. Ananya Kapoor & Sh. S. L. Chandani, Advs. Revenue by: Sh. Mithun Shete, Sr. DR Date of Hearing: 19.03.2025 Date of Pronouncement: 28.04.2025 ORDER Per Bench: These assessee’s and Revenue’s three cross appeals each involve the following relevant

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

Appeal is partly allowed in above terms

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

price at which the land was sold and whether the owner would have ever sold the land valuing it as a property yielding agricultural produce on the basis of its yield? At the risk of repetition, we may mention that not all of these factors would be present or absent in any case and that in each case