decision of the Delhi Bench of the Tribunal in the case of McDermott International ... case of the assessee is squarely covered with the aforesaid case of McDermott International Inc. (supra). He also contended that the case of National Petroleum
Mcdermott Etpm Inc. vs Deputy Commissioner Of Income Tax on 14 September, 2004
Equivalent citations: [2005]92ITD385(MUM), [2008]303ITR445(MUM), (2005)92TTJ
action of the Assessing
Officer (AO) that the India liaison office of McDermott
ETPM East Inc., a separate legal entity, constituted a
permanent establishment ... action of the AO
that Indian liaison office of M/s McDermott ETPM East
Inc., Dubai, a separate legal entity, constituted a permanent
establishment
case of Jt. DIT (OSD)
(International Taxation) v. J. Ray Mcdermott Eastern Hemisphere Ltd.] 42 SOT 26
(URO) wherein following observations have been made ... Similarly the Mumbai D-Bench of the Tribunal in the case of Mcdermott ETPM Inc.
v. Dy. CIT 92 ITD 385 held as follows
submission vessel "Jaya Vigilant" is time chartered by J Ray
McDermott SA (McDermott) for which agreement between assessee and McDermott
dated ... following details:
1. In respect of chartering of vessels to BGEPIL and McDermott, please submit the
followings:
a) Copy of charter agreements,
b) The specific
ordinate bench in the case of ACIT Int. Taxation vs. McDermott International
Management (in ITA Nos. 2373 & 2374/Del/2023 vide order dated ... Mitchell Drilling International Pvt. Ltd. (94 CCH 0031)
4. ACIT vs. McDermott International Management (ITA Nos. 2373 &
2374/Del/2023 vide order dated
Maritime(Mauritius) Ltd. [2011] 45 SOT
34 (Mum); and
iii) J Ray McDermott Eastern Hemisphere Ltd. v/s JCIT
operate outside India.
8. The Bombay High Court in the case of McDermott International Inc. v. Union of India and Ors. has held that taxation
permanent establishment of the
enterprise. In the case of McDermott Industries (Aust) Pty Ltd Vs
Commissioner of Federal Taxation 2 , even a barge was held
permanent establishment of the
enterprise. In the case of McDermott Industries (Aust) Pty Ltd Vs
Commissioner of Federal Taxation 2 , even a barge was held
