DIRECTOR OF INCOME TAX, INTERNATIONAL TAXATION, DELHIII, NEW DELHI Vs. ENRON GLOBAL EXPLORATION & PRODUCTION LTD C/O
HIGH COURT OF UTTARAKHAND
Director Of Income Tax, International Taxation, Delhiii, New Delhi
Enron Global Exploration And Production Ltd C/O
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(1.) This appeal, preferred under Section 260A of the Income Tax Act, 1961, is directed against order dated 24.10.2008, passed by the Income Tax Appellate Tribunal, Delhi Bench "G" New Delhi in ITA No. 861/Del/2005 (Assessment Year 2000-2001), whereby said court has dismissed the appeal of the Revenue.
(2.) Heard learned counsel for the parties, and perused the impugned order challenged before this Court.
(3.) Brief facts of the case are that the assessee Company iss incorporated in United States of America.
During the Assessment Year 2000-2001, the assessee earned revenue under its contract with M/s Enron Oil & Gas India Ltd. (for short EOGIL) in connection with oil and gas exploration and drilling activities. In the statement of income, the assessee company has mentioned "NIL", as income from the business, after claiming expenditure, on the ground that it has rendered services on cost to cost basis to EOGIL and received payments towards the reimbursement of expenses. It is also mentioned in the return that the transaction was covered under the provisions of Production Sharing Contract (for short PSC), which EOGIL has entered with the Indian concern.;
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