exploration and production

ONGC sought intervention of the PM in resolving the Russian tax puzzle

The tax structure is designed in a manner that the Russian government retains most of the revenues generated for crude prices above $30 resulting in low revenue for Imperial Energy, which is ONGC Videsh Ltd's wholly-owned UK-based subsidiary.
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Allowability of depreciation on participatory right in the nature of license

This article summarizes a recent ruling of the Delhi Income Tax Appellate Tribunal (ITAT) in the case of M/s ONGC Videsh Ltd. (Taxpayer) [2009-TIOL-758-ITAT-DEL] on the issue of allowability of depreciation on participatory right to carry out the hydrocarbon operations, acquired by the Taxpayer, pursuant to a Production Sharing Arrangement (PSA). The ITAT held that the participatory right acquired by the Taxpayer was in the nature of asset, in the form of 'license' i.e. ..
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AAR on importance of the transfer pricing provision over the capital gains provision

The AAR upholds the importance of the transfer pricing provision over the capital gains provision in case of an international transaction  In a recent ruling in case of Canoro Resources Limited1 (the taxpayer) the Authority for Advance Ruling (AAR) has held that   The transfer pricing provisions shall override the general provisions provided for computing capital [...]
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