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ETHERS FORMATION

A new pneumatic jacking system raised the unit's legs at one drilling location so that the rig could be moved to the next where the legs were lowered to the seafloor. At that point, the rig's deck was elevated above the sea surface. Santa Fe entered the offshore drilling business with a contract in Trinidad using a land rig adapted to a jackup barge and provided crews for a drillship offshore California.

It expanded drilling operations from the U. She was also the first self-propelled drillship to drill in Alaska's Cook Inlet and was later used in the Pacific in studies to evaluate mining of manganese nodules as part of the Deep Ocean Mining Project.

The Cuss-class drillships names were changed this year from Cuss to Glomar. Neptune Offshore was founded with capital from Forex and Languedocienne-Forenco. The world's first turret-moored drillship, Discoverer I, began operations. Global Marine placed the first public offerings of debenture and common stock as a Delaware company, providing it independence from Union Oil.

The Glomar Challenger began collecting seabed sediment cores around the world, a role that extended into Data collected allowed major advances in the theories of plate tectonics and continental drift. Schlumberger acquired a majority interest in Forex. Pentagone 81 was commissioned as the first semisubmersible rig built by Neptune of Forex, the French Petroleum Institute and the Hydrocarbon Support fund.

The rig later was called the Deepwater Navigator. The unit was contracted to the CIA for a secret mission, reported in the news media to be the recovery of a sunken Soviet submarine. Innovative drilling technology during this period led to new operations in offshore frontier areas, while mergers and acquisitions integrated some of the most experienced offshore drilling teams in the business.

Sonat Offshore Drilling, Inc. In December, Falcon Drilling Company became a publicly-traded company. Santa Fe celebrated its 50th anniversary. The company's ultra-deepwater and harsh environment floaters also made their mark with a string of world records. In addition, the company's ultra-deepwater drilling rigs made their mark in the s with a string of world records, including: - Discoverer Spirit — 7, feet of water, subsea completion record.

Deepwater Expedition — 9, feet, water depth record. Deepwater Millennium — 9, feet, water depth record. Discoverer Spirit — 9, feet, water depth record. Incurring of expenses, therefore, would be immaterial. Also, the contract was indivisible i Section 44BB starts with non-obstante clause, and the formula contained therein for computation of income is to be applied irrespective of the provisions of Sections 28 to 41 and Sections 43 and 43A of the Act.

It is not in dispute that assessees were assessed under the said provision which is applicable in the instant case. Sub-section 2 mentions two kinds of amounts which shall be deemed as profits and gains of the business chargeable to tax in India. Sub-clause a thereof relates to amount paid or payable to the assessee or any person on his behalf on account of provision of services and facilities in connection with, or supply of plant and machinery on hire used, or to be used in the prospecting for, or extraction or production of, mineral oils in India.

Thus, all amounts pertaining to the aforesaid activity which are received on account of provisions of services and facilities in connection with the said facility are treated as profits and gains of the business. This clause clarifies that the amount so paid shall be taxable whether these are received in India or outside India.

Clause b deals with amount received or deemed to be received in India in connection with such services and facilities as stipulated therein. Thus, whereas clause a mentions the amount which is paid or payable, clause b deals with the amounts which are received or deemed to be received in India. In respect of amount paid or payable under clause a of sub-section 2 , it is immaterial whether these are paid in India or outside India. On the other hand, amount received or deemed to be received have to be in India.

Thus, this provision contained in Section 44BB has to be read in conjunction with Sections 5 and 9 of the Act and Sections 5 and 9 of the Act cannot be read in isolation. This provision also treats this income as earned in India, fictionally, thereby satisfying the test of Section 9 of the Act as well.

Its purpose was explained by the Department vide its Circular No. However, the Legislature provided a simple formula, namely, treating the amounts paid or payable whether in or out of India and amount received or deemed to be received in India as mentioned in sub-section 2 of Section 44BB as the deemed profits and gains.

In these circumstances, the AO is supposed to apply the provisions of Section 44BB of the Act, in order to find out as to whether a particular amount is deemed income or not. It does not mention that the same is for reimbursement of expenses. In fact, it is a fixed amount paid which may be less or more than the expenses incurred. It is also to be borne in mind that the contract in question was indivisible. Having regard to these facts in the present case as per which the case of the assessees get covered under the aforesaid provisions, we do not find any merit in any of the contentions raised by the assessees.

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Management[ edit ] Oneworld announced formation of a central alliance team, the Oneworld Management Company oMCin Februaryto mark the alliance's first anniversary.

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