RESERVED JUDGMENT COURT NO.2 IN THE HIGH COURT OF UTTARANCHAL AT NAINITAL INCOME TAX APPEAL NO.443 OF 2001 (Old No.331 of 2000) 1. The Commissioner of Income Tax, Meerut 2. Deputy Commissioner of Income Tax (Assessment), Special Range-1, Dehradun ………….. Appellants Versus M/s O.N.G.C. as agent of M/s Hundai Corporation & Hundai Heavy Industries, Tel Bhawan, Dehradun …………… 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 appeal is allowed. The question is answered in favour of the Revenue. (J.C.S. Rawat, J.) (P.C. Verma, J.) Rajeev Dang