New Delhi, Oct. 18 -- The Supreme Court on Friday ruled that a foreign company cannot be said to have stopped doing business in India merely because it has no office or active contract in the country, holding that such a narrow view undermines India's global trade ambitions and ease of doing business goals. A bench of justices Manoj Misra and Joymalya Bagchi said that in an era of globalisation, the life blood of which is transnational trade and commerce, courts must adopt a pragmatic approach consistent with contemporary business realities. To hold that a non-resident company making business communications with an Indian entity from its foreign office is deemed to have ceased business activities in India, the judgment authored by Justice Bagchi noted, is "wholly anachronistic with India's commitment to the sustainable development goal relating to ease of doing business across national borders." The court's observations came while setting aside a Uttarakhand High Court order that had disallowed business expenditure deductions claimed by Pride Foramer SA, a French oil drilling company, on the ground that it was not carrying on business in India during the relevant assessment years. The top court restored the orders of the Income Tax Appellate Tribunal (ITAT), which had allowed the deductions, and directed the Assessing Officer to pass fresh assessment orders accordingly. Pride Foramer SA, incorporated in France, had been engaged in offshore oil drilling for the Oil and Natural Gas Corporation (ONGC) under a 10-year contract from 1983 to 1993. Although it failed to secure a subsequent contract until 1998, the company continued to maintain business correspondence with ONGC from its offices in Dubai and France, including submitting an unsuccessful bid for oil exploration in 1996. During this lull, the company incurred various expenditures, including administrative charges, audit fees, and other operational costs, aimed at sustaining its business operations and securing tax refunds. For the relevant assessment years (1996-97, 1997-98 and 1999-2000), it filed returns showing 'nil' income but sought to claim deductions for these expenditures and carry forward unabsorbed depreciation....