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2014 (5) TMI 151 - HC - Income TaxEstablishment of Permanent Establishment – Rig operated for the clients in India - Held that:- The Tribunal rightly was of the view that the word ‘used’ has been sufficiently explained in the Agreement requiring no further explanation - there is no scope of entering into the Income Tax Act as the word ‘used’ has been used in conjunction of ‘an installation or structure for exploration or exploitation of natural resources and only if so used for a period of more than 120 days in 12 month period’ - it is absolutely clear that the Agreement meant user of installation and structure for exploration or exploitation of natural resources and not merely being ready for use – the order of the Tribunal is upheld – Decided against Revenue.
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