OIL INDIA LTD. Vs. COMMISSIONER, COMMERCIAL TAXES, ORISSA

JUDGEMENT

(1.) AS all the writ petitions raise identical question of facts and law, they were heard together and are being disposed of by this common judgment.

(2.) FOR the purpose of brevity, the scope of challenge in various writ applications are narrated hereunder :

(3.) THE material facts of the case are, that by a contract dated 17.12.1982 which was extended by a subsequent contract dated 26.9.1985 between the petitioner and the PMM,SA, the petitioner, which was entrusted with the work of drilling exploratory oil wells in the Bay of Bengal, got the same wells drilled through PMM,SA. The said drilling operation with the drilling vessels of PMM,SA called AZTECA was carried on in the Bay of Bengal. It was admittedly carried on beyond 12 nautical miles from the Bay of Bengal and after the said drilling operations were completed the said vessels left the Country in the year 1986.