indirectly, through or from any business connection occurred in Section 42 of the Income Tax Act, 1922 as well. To this extent, remarks of the High Court may not be correct. 20000 of 2015, SLP(C). In that situation, only the mobilization fee pertaining to voyage within the territorial waters of India can be subjected to tax. 4925 OF 2010 civil appeal. 21939 OF 2017) civil appeal. Where payments are made to a non-resident outside India, for services rendered outside India, 3 (1986) 159 ITR 203 4 (1954) 25 ITR 27 (SC) 5 (2007) 288 ITR 408 (SC) (2007) 3 SCC 481) 6 (1977) 108 ITR 335 (SC) 7 (1966) 60 ITR. It is clear from the language used in Section 44BB(2 a) that the amount referred to in Section 44BB(1) on which profits have to be calculated @10 will be the aggregate of amounts paid or payable to the taxpayer or to any person on his. The provisions of Section 44BB were amended by the Finance Act, 1988 with retrospective effect.e.f.
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It has not been shown as to why the persons carrying on business in the particular goods specified in section 44AC are denied the reliefs available to others. Joint Commissioner of Income Tax, Special Range 1, Bangalore 10 and Commissioner of Income Tax Bihar and Orissa, Patna. According to them, since the payments were made by ongc to the assessee in terms of indivisible contract for the purposes of drilling operations, it was not open to the assessee to claim that mobilisation 24 fee/charges and it should not be included in the. Chidananda and Arijit Prasad, learned advocates appearing for the Revenue put up an emphatic defence to the judgment of the High Court which has accepted the position taken by the Revenue.
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32) It also noted that apart from the aforesaid mobilisation fee stipulated in the aforesaid two contracts, the ongc had undertaken to pay compensation based on operating rate of US 24,550 per 24 hours a day for all operating time and US 24,060 as non. Author: A Sikri, bench: A Bhushan, A Sikri 1 reportable IN THE supreme court OF india civil appellate jurisdiction civil appeal. According to him, the work undertaken was, in fact, the obligation of the ongc and it was for ongc to provide such facilities/material under the contract. Ashoka Marketing.11 29) Before we appreciate the rival submissions made by counsel for 10 (2015) 14 SCC 732 11 (1972) 4 SCC 426 28 the parties on both sides, it would be apposite to go into the raison detre behind the orders of the. As mentioned therein or to be governed by Section 44BB of the Act. Sub-clause (a) thereof relates to amount paid or payable to the assessee or any person on his behalf on account of provision of services and facilities in connection with, or supply of plant and machinery on hire used, or to be used in the prospecting. Section 5 deals with the scope of total income. Relevant portion of that circular is as under:.1 A number of complications are involved in the computation of taxable income of a taxpayer engaged in the business of providing services and facilities in connection with or supply of plant and machinery on hire, used. In the case of Transocean Offshore Inc., the itat upheld the view taken by the assessee and directed the AO to assess the profits on mobilisation charges at 1 of the amount received. Jay Savla, learned advocates appearing for some other assessees treaded the same path by adopting same line of arguments.