citedby: 1740194

Bg Exploration & Production India Ltd., ... vs Dcit, International Taxation, ... on 17 July, 2018

So, in view of the law laid down by the Hon'ble Apex Court in case of CIT vs. Enron Oil & Gas Limited (supra), we are of the considered view that the income earned by the taxpayer in foreign currency pursuant to the PSC entered into with Government of India is governed by the agreement of PSC and the foreign exchange losses on account of foreign currency translation is an allowable deduction while computing the total income of the taxpayer. In such circumstances, provisions of PSC are to be applied and the disallowance made by AO/DRP on 46 ITA No.6791/Del./2017 account of difference in revenue is not sustainable, hence allowable subject to verification by the AO. So, ground no.21 is determined in favour of the taxpayer for statistical purposes. GROUND NO.22

Income Tax Appellate Tribunal - Delhi Cites 38 - Cited by 2 - Full Document

Bg Exploration & Production India Ltd., ... vs Dcit, International Taxation, ... on 3 April, 2019

So, in view of the law laid down by the Hon'ble Apex Court in case of CIT vs. Enron Oil & Gas Limited (supra), we are of the considered view that the income earned by the taxpayer in foreign currency pu rsuant to the PSC entered into with Government of India is governed by the agreement of PSC and the foreign exchange losses on account of foreign currency translati on is an allowable deduction while computing the total income of the taxpayer. In such circumstances, provisions of PSC are t o be applied and the disallowance made by AO/DRP on account of difference in revenue is not sustainable, hence allowable subject to verifica tion by the AO. So, ground no.21 is determined in favour of the taxpaye r for statistical purposes."

Income Tax Appellate Tribunal - Delhi Cites 26 - Cited by 7 - Full Document

Hardy Exploration And Production ... vs Assessee on 15 September, 2010

8. On merits it was submitted by the learned DR that all the assessments which were in appeal before this Tribunal were liable to be sent back to the Assessing Officer for re-consideration in line with the decision of the Hon'ble Supreme Court in the case of CIT v. Enron Oil And Gas India Ltd., reported in 305 ITR 75 (SC) wherein the Hon'ble Supreme Court has held as follows :

Income Tax Appellate Tribunal - Chennai Cites 68 - Cited by 0 - Full Document

Vedanta Ltd (Successor To Cairn India ... vs Acit, Circle-26(1), New Delhi on 12 February, 2019

54. However, we are of the considered view that when the taxpayer is a designated operator of PSC who has always kept money in advance as a cash call for and on behalf of its members. Hon'ble Supreme Court in case cited as in CIT vs. Enron Oil & Gas Ltd. (supra) has held as to how the PSC works, the operative part of the judgment is extracted for ready perusal as under :-

Income Tax Appellate Tribunal - Delhi Cites 40 - Cited by 0 - Full Document