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Sec. 44BB

Uttaranchal H.C : Mobilization charges of 2.0121 per cent being charges in respect of voyage conducted in Indian Territorial Water only be included in the gross revenues and remaining amount of mobilization charges not to be part of gross revenues for the purposes of computation of income under section 44BB

Avijit Das / February 16, 2009

High Court Of Uttaranchal CIT, Dehradun vs. Sundowner Offshore International (Burmuda) Ltd. Assessment Year : 2004-05 Section : 44BB B.C. […]

Uttarakhand H.C : the AO as well as CIT(A) were right in adding the amount of Rs. 99,04,000 for the asst. yr. 1986-87 and amount worth Rs. 64,64,530 for the asst. yr. 1987-88 received by the assessee towards mobilization charges for the purpose of imposing income-tax

Avijit Das / September 28, 2007

High Court Of Uttarakhand Sedco Forex International Inc. vs. CIT & ANR. Section 44BB Asst. Year 1986-87, 1987-88 P.C. Verma

Income Tax Case Laws, Sec. 44BB, Section 44, Section 5, Section 9, Section 90

S.C : the contract in question was divisible contract. According to the Tribunal, the work of fabrication in Korea was separate from the work of installation and commissioning of platform in India

Avijit Das / May 18, 2007

Supreme Court Of India CIT & ANR. vs. Hyundai Heavy Industries Co. Ltd. Sections 5, 9, 44BB, 90, DTAA between

Sec. 44BB, Section 90

Uttaranchal H.C : Whether the learned Tribunal has erred in law in holding that the appellants have failed to satisfy the condition that ‘the remuneration is not deductible in computing the profits of an enterprise chargeable to tax in that other State’ ?

Avijit Das / July 22, 2005

High Court Of Uttaranchal Sedco Forex International Inc. vs. CIT IT Appeal Nos. 163 to 166, 168 to 172, 174

Sec. 28(iv), Sec. 44BB

Rajasthan H.C : Whether on the facts and in the circumstances of the case, the Tribunal is legally justified in : upholding the order of the learned CIT(A) who held that the amount of corporate tax paid by the OIL on behalf of the company falls under s. 44B(2) and therefore, only 10 per cent of that amount may be treated as income of the assessee. observing that the amount of corporate taxes paid by the OIL on behalf of the non-resident company does not amount to perquisite within the meaning of s. 28 (iv) ?

Avijit Das / July 15, 2003

High Court Of Rajasthan CIT vs. Compaigne General-Degeophysique Through Oil India Sections 28(iv), 44BB Asst. Year 1985-86, 1986-87, 1987-88, 1988-89

Rajasthan H.C : All these cases relate to the assessment of Oil and Natural Gas Commission (hereinafter referred to as ‘ONGC’) as agent of non-resident assessee M/s Compagnie Generals Deo Gophysique, France (in short ‘CGG’).

Avijit Das / November 2, 2001

High Court Of Rajasthan CIT vs. Oil And Natural Gas Commission Sections 44BB, 256(2) Rajesh Balia & Harbans Lal, JJ.

Sec. 44BB, Section 154

Calcutta H.C : Whether, on the facts and in the circumstances of the case, the Tribunal was justified in law in holding that where tax payable on behalf of the assessee was not included in the order under s. 143(3), the inclusion of the same in the order under s. 154 was a debatable issue and was not within the jurisdiction of s. 154 of the IT Act, 1961 ?

Avijit Das / September 17, 1997

High Court Of Calcutta CIT vs. Schlumberger Sea Co. Inc. Sections 44BB, 154, 256(2) Asst. Year 1983-84, 1984-85, 1985-86, 1986-87,

AAR : Whether remuneration paid to employees [residents of Australia] of the applicant satisfies sub-cl. (c) of cl. 2 of Art. 15 of the Agreement for Avoidance of Double Taxation (‘DTA’) concluded between India and Australia

Avijit Das / April 30, 1997

Authority For Advance Rulings LLoyd Helicopters International Pty. Ltd., In Re Sections 44BB, 44BBA, 245N(a) S. Ranganathan, J., Chairman; Bhuvanendra

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