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Presumptive taxation of oilfield services applies to receipts inextricably connected with mineral-oil operations, while qualifying offshore supplies remain untaxed.
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Oilfield service receipts from facilities, field-development consultancy and NDR preparation fall within section 44BB where they are inextricably connected with mineral-oil prospecting, extraction or production; those receipts are therefore taxable under the presumptive regime. Income-tax refund interest earned by a US resident is business profit under Article 7 of the India-US DTAA, rather than concessional interest income, when the refunded tax debt is effectively connected with its Indian permanent establishment. Consideration for offshore equipment supplies is not taxable in India where title and risk pass abroad, payment is received abroad, and no Indian operations, business connection or relevant permanent establishment exist.
Oilfield service receipts from facilities, field-development consultancy and NDR preparation fall within section 44BB where they are inextricably connected with mineral-oil prospecting, extraction or production; those receipts are therefore taxable under the presumptive regime. Income-tax refund interest earned by a US resident is business profit under Article 7 of the India-US DTAA, rather than concessional interest income, when the refunded tax debt is effectively connected with its Indian permanent establishment. Consideration for offshore equipment supplies is not taxable in India where title and risk pass abroad, payment is received abroad, and no Indian operations, business connection or relevant permanent establishment exist.
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