Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2021 (7) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2021 (7) TMI 182 - AT - Income TaxAddition of contractual revenue on protective basis in the hands of the assessee - case of the assessee was selected for scrutiny and AO passed the assessment order and proposed to complete the assessment holding that the consortium between TODDI and SASL (Assessee) constituted an Association of Person (AOP) under the provisions of the Act - HELD THAT:- In earlier assessment years, the Tribunal has been taking a consistent view that the Consortium agreement between the assessee and Transocean Offshore Deepwater Drilling Private Limited do not constitute an AOP and the Transocean Offshore Deepwater Drilling Inc. being consortium member has rightly offered to tax the receipts under section 44BB of the Act in the return of income. On the face of this consistent view taken by the Tribunal over a period of time, there is no reason for us now to take a different view since there is no change of circumstances to affect the applicability of this consistent view for the years under consideration in these two appeals. Allow the grounds of appeal in these two appeals also.
|