to the designated platform 'NV' to which the provisions. The stay is subject to the further condition that the applicant gives notice in writing so as to reach the Commissioner of Customs, 15 days prior to the rig leaving the designated area where it is presently located, and one month where the rig. DB Engineer of M/s. Therefore, in the first instance it is to be seen whether a particular income arises or accrues or deem to arise or accrue within India. The bond and the bank guarantee has to be furnished within a month of receipt of this order. The assessees filed their return of income declaring income from charter higher of the rig. In this batch of appeals, Civil Appeal. Before we appreciate the rival submissions made by counsel for the parties on both sides, it would be apposite to go into the raison detre behind the orders of the itat as well as the High Court.
(iii) Operational charges reimbursement. Explanation 1(a) to Section 9(1 i) of where to get my bitcoin address the Act provides an exclusion in the case of operations which are not carried out in India. The contract indisputably involved: (i) offshore supply, (ii) offshore services, (iii) onshore supply, (iv) onshore services and (v) construction and erection. Instead of going into the nitigrities of such computation as per the normal provisions contained in Sections 28 to 41 and Sections 43 and 43A of the Act, the Legislature has simplified the procedure by providing that tax shall be paid @10 of the aggregate. Union of India and Ors., (iv) Shiva Marketing. Of the amount specified in sub-section (2) of section 44BB. In the event that Operator desires to mobilize the Drilling Unit to another location offshore India and it fails to notify Contractor by such date, any additional costs incurred by Contractor for such mobilisation in excess of the Mobilisation Fee shall be borne by the. The assessees are companies incorporated outside India and, therefore, non-resident within the meaning of Section 6 of the Act. We very respectfully submit that in the judgment Ishikawajma-Harima Heavy Industries Ltd. The applicant in any case would undertake to inform the department well in advance of its movement outside India. The aforesaid agreements provided for the scope of work along with separate consideration for the work undertaken. Sedco, forex, international Inc.