Director Of Income Tax v. M/S Sedco Forex International Drilling Inc

IN THE HIGH COURT OF UTTARAKHAND AT NAINITAL Income Tax Appeal No. 07 of 2014 Director of Income Tax ...Appellant Vs. M/s Sedco Forex International Drilling Inc. ...Respondent Shri H.M. Bhatia, learned counsel for the appellant. Shri P.R. Mullick, learned counsel for the respondent. 20[th] November, 2020 Coram: Hon’ble Ravi Malimath, A.C.J.Hon’ble Ravindra Maithani, J. Ravi Malimath, A.C.J. (Oral) Five substantial questions of law have been raised for consideration in this appeal. Shri Hari Mohan Bhatia, learned counsel for the appellant and Shri P.R. Mullick, learned counsel for the respondent, submit that the questions of law that arise for consideration in this appeal have since been decided by the order of the Full Bench of this Court in Director of Income Tax International Taxation and Ors. Vs. Schlumberger Asia Services Ltd. and Ors. reported in414 ITR Page 1, in terms whereof, the questions of law have been answered against the revenue and in favour of the assessee. 2. In view of the submission made by the learned counsels, the questions of law that arise in this appeal are also answered in favour of the assesse and against the revenue by following the order of the Full Bench of this Court in Director of Income Tax International Taxation and Ors. Vs. Schlumberger Asia Services Ltd. and Ors. reported in 414 ITR Page 1. 3. The income tax dismissed. appeal is accordingly (Ravindra Maithani, J.) (Ravi Malimath) 20.11.2020 A.C.J. A.C.J. 20.11.2020 R.P.