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taxable at all, in view of Article 7 of Double Taxation Avoidance Agreement. It was, thus, argued that income had to be computed as per the provisions of the Act. The rig was located in Singapore and accordingly, under the contract, mobilization fees of US1 million (equivalent.4,31,10,000/-) was payable by ongc to the appellant for and on account of mobilization/ movement of rig from Singapore to the offshore site at Mumbai. Even on the issue of reimbursement in M/s. It was also argued that in the case of presumptive income determination like Section 44BB, items of expenditure cannot be claimed separately, otherwise it would lead to double deduction as Section 44BB presumes that only 10 of the aggregate receipts is income and the remaining. A composite/indivisible contract was entered into, was arrived at by the itat and, therefore, matter had to be proceeded on that basis. Semisubmersible rigs were partially submerged below water and usually moored to the ocean floor for stability. Section 9 acknowledges principle of attribution of income under the Act.

Transocean - Home Offshore Drilling Contractors



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From 2004 to 2007, Transocean was the leader or near the top among deep-water drillers in "job quality" and "overall satisfaction." In 20, surveys ranked Transocean as last among deep-water drillers for "job quality" and next to last in "overall satisfaction." In 20, Transocean ranked. Fixed amount is agreed to be paid which is mentioned in the said Clause. 5152 OF 2011 civil appeal. Clearly, Transocean Sedco Forex had taken the lead in the consolidation of offshore drilling contractors. 11 In 2005, the company's Discoverer Spirit rig set a world record for the deepest offshore oil and gas well forex trading en direct tv of 34,189 ft (10,421 m). It enjoyed an immediate boost in price, caused in large part by money managers adding the stock to their funds that mirrored the S P 500. As a result, Offshore developed one of the largest.S.