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ITAT allowed the assessee's appeal, holding that, in line with the Del HC precedent, receipts from hiring rigs for prospecting, extraction or production of mineral oil fall within the special computation regime of s.44BB, thereby excluding application of s.9(1)(vi). The tribunal deleted the addition made by the AO and directed the AO to compute the assessee's income for the assessment years in dispute exclusively under s.44BB. The assessment framed by applying s.9(1)(vi) was set aside and the matter remitted for recomputation in accordance with s.44BB.
ITAT allowed the assessee's appeal, holding that, in line with the Del HC precedent, receipts from hiring rigs for prospecting, extraction or production of mineral oil fall within the special computation regime of s.44BB, thereby excluding application of s.9(1)(vi). The tribunal deleted the addition made by the AO and directed the AO to compute the assessee's income for the assessment years in dispute exclusively under s.44BB. The assessment framed by applying s.9(1)(vi) was set aside and the matter remitted for recomputation in accordance with s.44BB.
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