RESERVED JUDGMENT COURT NO.2 IN THE HIGH COURT OF UTTARANCHAL AT NAINITAL INCOME TAX APPLICATION NO.77 OF 2003 (Old No.110 OF 1997) The Commissioner of Income Tax, Meerut …..……. Applicant Versus M/s ONGC Ltd. as agent of M/s Dixilyn Field International Drilling Company ……… Respondent Sri S.K. Posti, Advocate, learned counsel for the appellants Sri J.P. Joshi, Advocate, learned counsel for the respondent Dated: December 15, 2005 Coram: Hon’ble P.C. Verma, J. Hon’ble J.C.S. Rawat, J. The facts and circumstances of the case are identical to the facts in Income Tax Appeal No.115 of 2001, Commissioner of Income Tax, Meerut and another Vs. M/s ONGC as agent of M/s Halliburton Offshore Services Inc. Tel Bhawan, Dehradun, which is being decided today. The substantial question which arises for our consideration has been answered in favour of the Revenue. Accordingly, the application is allowed. The question is answered in favour of the Revenue. (J.C.S. Rawat, J.) (P.C. Verma, J.) Rajeev Dang