High Court Upholds Tribunal's Decision: 119-Day Rig Presence Establishes Permanent Establishment u/s 44BB for Taxation Purposes.

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....Taxation u/s 44BB - Existence of PE - contractual income from GSPC under the contract - drilling services were continued only for a period of 119 days - When the rig had entered Indian waters and it was undergoing fabrication, upgradation and positioning for the drilling activity for GSPC it can be said that the PE was there in connection with the exploration, exploitation or extraction of mineral oils. - Order of ITAT confirming the additions sustained - HC....