IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “DB”NEW DELHI BEFORE SHRI YOGESH KUMAR US, JUDICIAL MEMBER AND SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER आ.अ.स/ं .I.T.A No.250/DDN/2025 िनधा(cid:9)रणवष(cid:9)/Assessment Year:2016-17 DY. COMMISSIONER OF INCOME TAX, बनाम HALLIBURTON WORLDWIDE GMBH Aayakar Bhawan, 13-A, Subhash Road, Vs. 1^st Floor, IDA, 46, E.C. Road, Dehradun, Uttarakhand. Dehradun- 248001,Uttarakhand.

PAN No.AADCH1061Q अपीलाथ(cid:20) Appellant (cid:22)(cid:23)यथ(cid:20)/Respondent Assessee by Shri Amit Arora, CA &Shri Vishal Mishra, CA Revenue by Shri Mohan Lal Joshi, Sr. DR सुनवाईक(cid:8)तारीख/ Date of hearing: 11.02.2026 उ(cid:14)ोषणाक(cid:8)तारीख/Pronouncement on 18.02.2026 आदेश /O R D E R PERSANJAY AWASTHI, ACCOUNTANT MEMBER:

1. The present appeal arises from order u/s 250 of the Income Tax Act, 1961 (hereafter “the Act”), dated 16.09.2025, passed by Ld. CIT(A)- Noida-2. In this case, the Ld. AO is seen to have held the receipts on account of IP Charges received from Halliburton Offshore Services Inc. amounting to Rs.77,66,43,479/- to be in the nature of “Royalty” u/s 9(1)(vi) of the Act, which has been held to be taxable u/s 115A of the Act. Notably the assessee had