Pgs Exploration (Norway) As vs Additioanal Director Of Income … on 8 April, 2016

1. PGS Exploration (Norway) AS (now known as ‘PGS Geophysical
AS’), a company incorporated under the laws of Norway (hereafter „the
Assessee‟), has filed the present appeal under Section 260A of the Income
Tax Act, 1961 (hereinafter „the Act‟) impugning the order dated 20.04.2012
passed by the Income Tax Appellate Tribunal (hereafter „the Tribunal‟) in
ITA No. 4056/Del/2011. The said appeal was directed against the
assessment order dated 29.07.2011 passed under Section 144C read with
Section 143(3) of the Act pursuant to directions of the Dispute Resolution
Panel (hereafter „DRP‟) issued on 18th July, 2011.

2. The principal controversy involved in the present appeal relates to

ITA No. 612/2012 Page 1 of 22
whether the consideration received by the Assessee for services rendered by
the Assessee to entities resident in India is “fees for technical services”
within the meaning of Explanation 2 to Section 9(1)(vii) of the Act; and,
whether the same is taxable under section 115A or Section 44BB of the
Act.

Source: Indian Kanoon

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