BG EXPLORATION & PRODUCTION INDIA LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, DDIT/ADIT (INTERNATIONAL TAXATION), CIRCLE -1, DEHRADUN

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

b. Thus it can be held that the assessee has carried out operations in India under the production sharing contracts. The functions of the project office are approved by RBI and the assessee cannot discharge any other function as per this approval. Under these contracts, the assessee carries out the operations as a Contractor, along with other independent entities