GLOBAL GEOPHYSICAL SERVICES LIMITED Vs. DIRECTOR OF INCOME TAX

JUDGEMENT

(1.) GLOBAL Geophysical Services Limited is the applicant company incorporated under the laws of Cayman Islands and therefore it is a non -resident. The applicant is engaged in the business of seismic data acquisition and processing for exploration companies on a worldwide basis. The seismic data (in processed form) is used to create highly accurate images of the earth's subsurface which in turn are used by the exploration and production companies for locating potential oil and gas reserves based upon the geology observed.

(2.) 1 The primary objective of 3D processing of seismic data acquired in the areas in the western offshore is to obtain accurate high resolution imaging with geological objectives prescribed under the ONGC contract. The ONGC contract was initially entered with a validity period upto May 31, 2009. However, the ONGC contract was extended for data acquisition activity upto December 31 2009 and for data processing activity upto February 28, 2010 since the applicant could not complete the contract within the stipulated period.

(3.) SHRI . Percy Pardiwala, learned Sr. Counsel, while arguing the case on behalf of the applicant, has reiterated the stand taken in the application and submitted that the services rendered by the applicant is for prospecting of mineral oil. He has supplied the meaning of the word "prospect" from the dictionary of Science and Technology wherein it means: