Income Tax Appellate Tribunal Itat Delhi Court May 1994 Judgments Home Cases Income Tax Appellate Tribunal Itat Delhi 1994 Page 1 of about 1 results (0.031 seconds)

G. Winpenny Vs. Income-tax Officer

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (1994)50ITD501(Delhi)

1. All these appeals are directed against separate orders passed by the Commissioner of Income-tax (Appeals) whereby he has upheld the action on the part of the Income-tax Officer in subjecting to tax the salary paid to the assessees by their employer for the 28 days off periods when they were physically off the rigs installed in Indian coastal waters.2. To set out the brief facts of the case, the appellants are foreign technicians, who have been deputed by their foreign employer, namely, M/s. Atwood Oceanics International S.A., to work on the rigs situated off the Indian coast pursuant to the contract entered into between the said foreign employer and ONGC.3. In the course of the assessment proceedings it was contended on behalf of the appellants that the salary for the off periods when they were off the rigs being physically outside India and the said salary having been paid outside India was not taxable in India. The aforesaid claim was rejected by the Income-tax Officer primarily ...