2014 (5) TMI 151

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....sti, Advocate for the respondent Barin Ghosh, C.J. (Oral) These Appeals arise from the selfsame order of the Tribunal, whereby the Tribunal dealt with three Appeals preferred by the assessee involving a similar question, but in relation to three different assessment years. The point in issue to be decided was, whether the assessee had a permanent establishment in India during the relevant as....

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....ould be culled out from the Income Tax Act, 1961, which includes 'ready for use' and felt that even during the time of repair and maintenance, the rig was lying ready for use and, as such, the rig having been used for more than 120 days during the relevant assessment years, the assessee, in the form of the said rig, had a permanent establishment in India in terms of the meaning of 'permanent estab....