COMMISSIONER OF INCOME TAX Vs. ONGC LTD.

JUDGEMENT

(1.) PASSED by the Income -tax Appellate Tribunal, Delhi Bench "G" (hereinafter referred as "the Tribunal"), whereby the CIT(A)"], is affirmed. The CIT(A) allowed the appeal of the assessee and set aside the assessment order passed by the AO under s. 143(3) of the IT Act, 1961.

(2.) HEARD learned counsel for the parities.

(3.) THE brief facts of the case are that Oil and Natural Gas Commission Ltd. (hereinafter referred as "the ONGC") is representative of the non -resident company (hereinafter referred as NRC) respondent assessee in the case. The assessee has rendered its services to ONGC for the purposes of exploration, extraction and production of mineral oils. During the asst. yr. 2001 -02, the assessee NRC rendered the following services to ONGC :