With Civil Appeal Nos.375 426, 428 447, 462, 465 472, 474 476, 478, 480 481, 483 484, 545, 502 511, 513 521, 526 530, 534 544,546 of 2005 RUMA PAL, J The appellant has filed these appeals as the agent of its employees who are the assessees in the present case.
It entered into a wet lease with the Oil and Natural Gas Commission ONGC under which the appellant agreed to supply oil rigs and the employees to man the rigs to enable ONGC to carry on offshore drilling within the territorial waters of this companyntry.
The appellant also entered into agreements which were executed in the United Kingdom with each of its employees who are residents of the United Kingdom.
The employees were to be paid the same monthly salaries for the alternating periods.
The appellant itself is a companypany which was incorporated in Panama.
