REEBOK INDIA COMPANY,GURUGRAM vs. JCIT (OSD), NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri N.K. Billaiya & Shri Kul Bharat

3) of the Act provides a time limit of six years from the end of the financial year in which payment / credit is made for passing of order under section 201(1) of the Act for cases in which TDS statement has not been filed. However, notice under section 148 of the Act may be issued for reassessment

CIT vs. SELECT HOLIDAY RESORTS PVT LTD

The appeals stand disposed of as above

Bench: HON'BLE MR. JUSTICE SANJIV KHANNA,HON'BLE MR. JUSTICE R.V.EASWAR

reassess under section 14 7 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001." Q 11. By Notification No.45/2008 dated 24/03/2008, the Central Board of Direct Taxes (CBDT), in exercise

CIT vs. SELECT HOLIDAY RESORTS PVT LTD

The appeals stand disposed of as above

reassess under section 14 7 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001." Q 11. By Notification No.45/2008 dated 24/03/2008, the Central Board of Direct Taxes (CBDT), in exercise

M/S BG EXPLORATION & PRODUCTION INDIA LTD.,MUMBAI vs. ITO (TDS), DEHRADUN

In the result, all the appeals filed by the assessee are partly allowed

Bench: Sh. N. K. Billaiya & Ms. Suchitra Kamble

3) The provisions of sub-sections (1), (1 A), (IB) and (2) shall not apply to the following classes of assessments, reassessments and recomputations which may, subject to the provisions of sub-section (2A), be completed at any time— . . . (ii') where the assessment, reassessment or recomputation is made on the assessee or any person in consequence of or to give

LG ELECTRONICS INDIA LTD.,GR. NOIDA vs. ITO (TDS) INTERNATIONAL TAXATION, NOIDA

In the result, appeals are allowed, as indicated above

Bench: Shri G.S. Pannu, Vice- & Shri Saktijit Dey, Vice-Assessment Year: 2005-06 With Assessment Year: 2006-07 With Assessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 With Assessment Year: 2010-11 With Assessment Year: 2011-12 M/S. Lg Electronics India Ltd., Vs. Ito (Tds), Plot No.51, Udyog Vihar, International Taxation, Surajpur Industrial Area, Noida Greater Noida (Up) Pan :Aaacl1745Q (Appellant) (Respondent)

3 | P a g e ITA Nos.7926 to 7930/Del/2018 AYs: 2005-06 to 2011-12 assessee preferred Writ Applications before the Hon’ble Allahabad High Court. While disposing of the said Writ Applications, the Hon’ble High Court set aside the orders passed by the Assessing Officer, by holding them to have been passed in violation of Rules of Natural

LG ELECTRONICS INDIA LTD.,GR. NOIDA vs. ITO (TDS) INTERNATIONAL TAXATION, NOIDA

In the result, appeals are allowed, as indicated above

Bench: Shri G.S. Pannu, Vice- & Shri Saktijit Dey, Vice-Assessment Year: 2005-06 With Assessment Year: 2006-07 With Assessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 With Assessment Year: 2010-11 With Assessment Year: 2011-12 M/S. Lg Electronics India Ltd., Vs. Ito (Tds), Plot No.51, Udyog Vihar, International Taxation, Surajpur Industrial Area, Noida Greater Noida (Up) Pan :Aaacl1745Q (Appellant) (Respondent)

3 | P a g e ITA Nos.7926 to 7930/Del/2018 AYs: 2005-06 to 2011-12 assessee preferred Writ Applications before the Hon’ble Allahabad High Court. While disposing of the said Writ Applications, the Hon’ble High Court set aside the orders passed by the Assessing Officer, by holding them to have been passed in violation of Rules of Natural

LG ELECTRONICS INDIA LTD.,GR. NOIDA vs. ITO (TDS) INTERNATIONAL TAXATION, NOIDA

In the result, appeals are allowed, as indicated above

Bench: Shri G.S. Pannu, Vice- & Shri Saktijit Dey, Vice-Assessment Year: 2005-06 With Assessment Year: 2006-07 With Assessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 With Assessment Year: 2010-11 With Assessment Year: 2011-12 M/S. Lg Electronics India Ltd., Vs. Ito (Tds), Plot No.51, Udyog Vihar, International Taxation, Surajpur Industrial Area, Noida Greater Noida (Up) Pan :Aaacl1745Q (Appellant) (Respondent)

3 | P a g e ITA Nos.7926 to 7930/Del/2018 AYs: 2005-06 to 2011-12 assessee preferred Writ Applications before the Hon’ble Allahabad High Court. While disposing of the said Writ Applications, the Hon’ble High Court set aside the orders passed by the Assessing Officer, by holding them to have been passed in violation of Rules of Natural

LG ELECTRONICS INDIA LTD.,GR. NOIDA vs. ITO (TDS) INTERNATIONAL TAXATION, NOIDA

In the result, appeals are allowed, as indicated above

Bench: Shri G.S. Pannu, Vice- & Shri Saktijit Dey, Vice-Assessment Year: 2005-06 With Assessment Year: 2006-07 With Assessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 With Assessment Year: 2010-11 With Assessment Year: 2011-12 M/S. Lg Electronics India Ltd., Vs. Ito (Tds), Plot No.51, Udyog Vihar, International Taxation, Surajpur Industrial Area, Noida Greater Noida (Up) Pan :Aaacl1745Q (Appellant) (Respondent)

3 | P a g e ITA Nos.7926 to 7930/Del/2018 AYs: 2005-06 to 2011-12 assessee preferred Writ Applications before the Hon’ble Allahabad High Court. While disposing of the said Writ Applications, the Hon’ble High Court set aside the orders passed by the Assessing Officer, by holding them to have been passed in violation of Rules of Natural

L.G. ELECTRONICS INDIA LTD., NOIDA vs. ITO, WARD- 2(2)(1)(INT. TAXATION), NEW DELHI

In the result, appeals are allowed, as indicated above

Bench: Shri G.S. Pannu, Vice- & Shri Saktijit Dey, Vice-Assessment Year: 2005-06 With Assessment Year: 2006-07 With Assessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 With Assessment Year: 2010-11 With Assessment Year: 2011-12 M/S. Lg Electronics India Ltd., Vs. Ito (Tds), Plot No.51, Udyog Vihar, International Taxation, Surajpur Industrial Area, Noida Greater Noida (Up) Pan :Aaacl1745Q (Appellant) (Respondent)

3 | P a g e ITA Nos.7926 to 7930/Del/2018 AYs: 2005-06 to 2011-12 assessee preferred Writ Applications before the Hon’ble Allahabad High Court. While disposing of the said Writ Applications, the Hon’ble High Court set aside the orders passed by the Assessing Officer, by holding them to have been passed in violation of Rules of Natural

LG ELECTRONICS INDIA LTD.,GR. NOIDA vs. ITO (TDS) INTERNATIONAL TAXATION, NOIDA

In the result, appeals are allowed, as indicated above

Bench: Shri G.S. Pannu, Vice- & Shri Saktijit Dey, Vice-Assessment Year: 2005-06 With Assessment Year: 2006-07 With Assessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 With Assessment Year: 2010-11 With Assessment Year: 2011-12 M/S. Lg Electronics India Ltd., Vs. Ito (Tds), Plot No.51, Udyog Vihar, International Taxation, Surajpur Industrial Area, Noida Greater Noida (Up) Pan :Aaacl1745Q (Appellant) (Respondent)

3 | P a g e ITA Nos.7926 to 7930/Del/2018 AYs: 2005-06 to 2011-12 assessee preferred Writ Applications before the Hon’ble Allahabad High Court. While disposing of the said Writ Applications, the Hon’ble High Court set aside the orders passed by the Assessing Officer, by holding them to have been passed in violation of Rules of Natural

LG ELECTRONICS INDIA LTD.,GR. NOIDA vs. ITO (TDS) INTERNATIONAL TAXATION, NOIDA

In the result, appeals are allowed, as indicated above

Bench: Shri G.S. Pannu, Vice- & Shri Saktijit Dey, Vice-Assessment Year: 2005-06 With Assessment Year: 2006-07 With Assessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 With Assessment Year: 2010-11 With Assessment Year: 2011-12 M/S. Lg Electronics India Ltd., Vs. Ito (Tds), Plot No.51, Udyog Vihar, International Taxation, Surajpur Industrial Area, Noida Greater Noida (Up) Pan :Aaacl1745Q (Appellant) (Respondent)

3 | P a g e ITA Nos.7926 to 7930/Del/2018 AYs: 2005-06 to 2011-12 assessee preferred Writ Applications before the Hon’ble Allahabad High Court. While disposing of the said Writ Applications, the Hon’ble High Court set aside the orders passed by the Assessing Officer, by holding them to have been passed in violation of Rules of Natural

ACIT, NEW DELHI vs. M/S. VISION TOWN PLANNERS PVT. LTD., NOIDA

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing)

201 301. PAN: AACCV9600Q (Appellant) (Respondent) Assessee by : Shri Rakesh Joshi, C. A.; Department by: Ms. Sunita Singh [CIT] – D. R.; Date of Hearing : 17/09/2021 Date of pronouncement : 18/11/2021 O R D E R PER AMIT SHUKLA , J. M. 1. This appeal has been filed by the Asst Commissioner of income tax, Central Circle – 23, New Delhi (the learned

DCIT, DEHRADUN vs. M/S. EXPRO GULF LTD., MUMBAI

In the result, the appeal of the Revenue is partly allowed for statistical

Bench: : Shri H.S. Sidhu & Shri L.P. Sahu

3. The phrase "in connection with" used in section 44BB only broadens the scope of the section to cover services which are not of technical nature and enacts a special provision for determination of tax liability of persons engaged in providing such services which would be outside the scope of technical services. 4. Instruction No. 1862 dated

BEST BULL STOCK TRADING PVT LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE-18, DELHI

In the result, the appeals of the revenue in ITA No

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

3), Nagpur." 10. Direction of the higher authority including that of the CIT(A) will not confer power to assume jurisdiction to the AO to initiate reassessment proceeding. With this considered view, on a total in-depth study of the case laws and considering the rival submissions, we allow the assessee's appeal and cancel the order

BEST BULL STOCK TRADING PVT LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-18, NEW DELHI

In the result, the appeals of the revenue in ITA No

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

3), Nagpur." 10. Direction of the higher authority including that of the CIT(A) will not confer power to assume jurisdiction to the AO to initiate reassessment proceeding. With this considered view, on a total in-depth study of the case laws and considering the rival submissions, we allow the assessee's appeal and cancel the order

ADIT, DEHRADUN vs. M/S. HALLIBURTON OFFSHORE SERVICES INC., DEHRADUN

Bench: Shri I.C.Sudhir & Shri Prashant Maharishiadit, Halliburton Offshore Services International Taxation, Inc. , Vs. 13-A,Subhash Road, C/O. Nangia & Company, Ca, Aayakar Bhawan, 75/7, Rajpur Road, Dehradun Dehradun Pan:Aaach5154M (Appellant) (Respondent) Halliburton Offshore Services Addl. Cit, Inc. , International Taxation, Vs. C/O. Nangia & Company, Ca, Subhash Road, Suite-4A, Plaza M-6, Jasola, Dehradun New Delhi Pan:Aaach5154M (Appellant) (Respondent) Halliburton Offshore Services Inc. , Adit, C/O. Nangia & Company, Ca, International Taxation, Vs. Suite-4A, Plaza M-6, Jasola, 13-A,Subhash Road, New Delhi Aayakar Bhawan, Pan:Aaach5154M Dehradun (Appellant) (Respondent) Halliburton Offshore Services Inc. Vs Ddit (International Taxation)

reassessment, caused the payer to erroneously refrain from deducting tax under Section 195; it must thus suffer an interest for non-payment of advance tax. The case of the assessees on the other hand is that the position of law in Jacabs Civil Incorporated/Mitsubishi Corporation (supra) must apply, and that the obligation was upon the payer to deduct

DIRECTOR OF INCOME TAX INTERNATIONAL TAXATION vs. GE PACKAGED POWER INC

3. The assessees appealed against the order of the AO; the CIT(A) disposed of the appeals by its order of 30.9.2010, confirming the reopening of the assessment, the finding on existence of PEs in India, and the attribution of profits to the PEs. However, on the question of interest under Section 234B for failure to pay advance

CAIRN UK HOLDING LTD.,AHMEDABAD vs. DCIT (INTERNATIONAL TAXATION), NEW DELHI

In the result ground No. 5 of the appeal of the assessee is allowed

Bench: Shri H. S. Sidhu & Shri Prashant Maharishi

Section 148, the reassessment had been initiated without any basis and information and as such the same is liable to be quashed. Furthermore, as noted above, no new documents were discovered by the survey proceedings in January 2014 - all of the documents in question had been in the hands of the government in 2006. The reason that