Автор: Munris
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First, Transocean moved its headquarters from Houston to the foot of the Swiss Alps in early , in a move mainly aimed at saving on taxes. Then came a top management reshuffle and retirement of its eminent, but media-shy chief executive, Bob Long.
Long spent 34 years working for Transocean or predecessor companies, and as a Naval Academy graduate, shared the U. So Newman, formerly the chief operating officer and a Harvard Business School graduate like Long, was already stepping into some large shoes. He was succeeded by an Oxford-educated senior vice president, Ricardo Rosa, who was already based in Europe.
That all followed the abrupt retirement of another COO, Jon Marshall, who was also in line to be boss, indicating that the year-old Newman has a proven ability to survive boardroom politics. He was a petroleum engineering major at the Colorado School of Mines, who has held numerous roles in his 16 years at Transocean ranging from rig manager to regional manager, so his past public comments tended to focus on technical issues.
Noble Corp followed it, along with a few other companies with few fixed U. Three years later came a merger with Sedco Forex, spun off by oil services company Schlumberger. A blockbuster deal for GlobalSantaFe in created an industry leader. In a twist on its move to Switzerland, which has succeeded in cutting its tax bill, the company's cash management is now open to scrutiny with the weekly online publication of its share buybacks.
Reporting by Braden Reddall. This provision also treats this income as earned in India, fictionally, thereby satisfying the test of Section 9 of the Act as well. Its purpose was explained by the Department vide its Circular No.
However, the Legislature provided a simple formula, namely, treating the amounts paid or payable whether in or out of India and amount received or deemed to be received in India as mentioned in sub-section 2 of Section 44BB as the deemed profits and gains. In these circumstances, the AO is supposed to apply the provisions of Section 44BB of the Act, in order to find out as to whether a particular amount is deemed income or not. It does not mention that the same is for reimbursement of expenses.
In fact, it is a fixed amount paid which may be less or more than the expenses incurred. It is also to be borne in mind that the contract in question was indivisible. Having regard to these facts in the present case as per which the case of the assessees get covered under the aforesaid provisions, we do not find any merit in any of the contentions raised by the assessees.
Therefore, the ultimate conclusion drawn by the AO, which is upheld by all other Authorities is correct, though some of the observations of the High Court may not be entirely correct which have been straightened by us in the above discussion. For our aforesaid reasons, we uphold the conclusion. Resultantly, all the appeals of the assessees are dismissed. Vaman International Pvt. By submitting confirmation letters, copies of invoices, bank statement, payment order, payment by account payee cheques etc.
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