DDIT, DEHRADUN vs. BG EXPLORATION & PRODUCTION INDIA LTD., MUMBAI
In the result ground No. 2 of the appeal of the assessee is dismissed
ITA 2227/DEL/2014[2009-10]Status: DisposedITAT Delhi26 Apr 2017AY 2009-10
Bench: Shri I. C. Sudhir & Shri Prashant Maharishidy. Director Of Income Tax, Bg Exploration & Production India International Taxation, Ltd, Dehradun Bg House, Vs. Lake Boulevard Road, Hiranandani Business Park, Powai, Mumbai Pan: Aaace4569K (Appellant) (Respondent)
For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. NC Swain, CIT DR
Section 143(3)Section 144CSection 92
9) Such highly technical experts may not be required by assessee all the time. Thus, economically and commercially unviable for assessee to employ such personnel on permanent basis. Hence, need based support obtained.
10) Assessee's prerogative to use services from Group enterprises or / and third parties -directing the assessee on how to conduct its business operations is beyond