Section 44BB gross receipts include reimbursed expenses linked to mineral oil services, increasing the presumptive tax base.

Reimbursements of actual expenses received by a non-resident assessee from customers were held to form part of gross receipts for computation under section 44BB of the Income-tax Act. The jurisdictional High Court's view that section 44BB is a complete code for presumptive taxation in relation to services and facilities connected with mineral oil exploration was applied, so all amounts received or receivable in connection with such services were included in the aggregate receipts for deemed profit computation. Because the reimbursements were inextricably linked to the services rendered, they could not be excluded from the taxable base, and the issue was decided against the assessee.

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Issues: Whether reimbursements of actual expenses received by a non-resident assessee from customers form part of gross receipts for computation of income under section 44BB of the Income-tax Act, 1961.

Analysis: The appeal was covered by the jurisdictional High Court's ruling that section 44BB is a complete code for presumptive taxation of profits from services and facilities in connection with mineral oil exploration, and that all amounts received or receivable in connection with such services fall within the aggregate receipts on which deemed profits are computed. The reimbursements in question were found to be inextricably linked with the services rendered and therefore could not be excluded from the taxable base under section 44BB.

Conclusion: The reimbursements were includible in the gross receipts for computation under section 44BB, and the issue was decided against the assessee.

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