M/S Transocean Offshore International Ventures Limited v. Income Tax Appeal

IN THE HIGH COURT OF UTTARAKHAND AT NAINTALINCOME TAX APPEAL NO. 10 OF 2015 M/s Transocean Offshore International Ventures Limited ……..Appellant. Versus The Assistant Director of Income Tax, International Taxation, Dehradun. ……Respondent & INCOME TAX APPEAL NO. 11 OF 2015 M/s Transocean Offshore Discoverer 534 LLC ……..Appellant. Versus The Assistant Director of Income Tax, International Taxation, Dehradun. ……Respondent Mr. S.K. Posti, Advocate for the appellants. Mr. Hari Mohan Bhatia, Advocate for the respondent. Dated: 25.02.2015 Coram:Hon’ble K.M. Joseph, C.J. Hon’ble V.K. Bist, J. Hon’ble K.M. Joseph, C.J. (Oral) Since questions of law involved in these Appeals are same, both these are being disposed of by this common order. 2. Substantial Question of Law No. (b) relating to mobilization charges being included in Section 44BB of the Income Tax Act is covered against the appellants by virtue of the decision of this Court reported in 299 ITR 238 (Sedco Forex International Inc. Vs. Commissioner of Income Tax and another). As far as Substantial Question No. (c) is concerned, the learned counsel for the appellants himself would submit that the issue is covered against the appellants by virtue of the decision of this Court reported in 300 ITR 265 (Commissioner of Income Tax and another Vs. Halliburton Offshore Services Inc.). 3. In view of the above submissions made by the learned counsel for the appellants, we see no reason to entertain these Income Tax Appeals. Both the Income Tax Appeals are dismissed. (V.K. Bist, J.) (K.M. Joseph, C.J.) 25.02.2015 25.02.2015 Rathour