Central Govt. agencies in agreement with foreign companies are not entitled to exemption of surtax

Issue before Court: Whether certain govt. agencies (ONGC) in agreement with foreign companies would entitle for the exemption of surtax under notification no. GSR 307 (E) dated 3.1983. Brief facts: ONGC (A person authorised by central govt. by notification dated 02.08.1989) had executed agreements with different foreign companies for services or facilities or for supply of ship, aircraft, machinery and plant, as may be, all of which were to be used in connection with the prospecting or extraction or production of mineral oils. Such agreements do not contemplate a direct association or partici...