Repairs and mobilization of rigs not to be included for the purpose of calculating 120 days to constitute an installatio

Repairs and mobilization of rigs not to be included for the purpose of calculating 120 days to constitute an installation PE- rules Delhi Tax Tribunal Source: R & B Falcon Offshore Ltd Vs. ACIT Dehradun, ITAT Delhi (2011-TII-02-ITA T-DEL-INTL) Facts •           R B Falcon Drilling Co USA (“RBF”), a non-resident foreign company, was engaged in business as an offshore drilling contractor. In terms of an agreement with Petrom S.A., it had to execute a contract relating to drilling including mobilizing of rig in India. In the contract, RBF had given an address in India as the...