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ITAT upheld the CIT(A)'s determination that the assessee's receipts are taxable under Section 44BB of the Act (business profits linked to extraction/exploration of mineral oil) and are not liable as royalty/FTS under Sections 9(1)(vi)/9(1)(vii) read with Section 44DA. Relying on a prior coordinate-bench decision in the assessee's own case and finding the requisite nexus with oil exploration and a PE in India, the Tribunal dismissed Revenue's substantive objection and Revenue Ground No.1. ITAT also confirmed that interest under Section 244A on tax refunds is taxable at 15% under the applicable DTAA, endorsing the CIT(A)'s approach; Revenue Grounds No.2 and 2.1 were accordingly dismissed.
ITAT upheld the CIT(A)'s determination that the assessee's receipts are taxable under Section 44BB of the Act (business profits linked to extraction/exploration of mineral oil) and are not liable as royalty/FTS under Sections 9(1)(vi)/9(1)(vii) read with Section 44DA. Relying on a prior coordinate-bench decision in the assessee's own case and finding the requisite nexus with oil exploration and a PE in India, the Tribunal dismissed Revenue's substantive objection and Revenue Ground No.1. ITAT also confirmed that interest under Section 244A on tax refunds is taxable at 15% under the applicable DTAA, endorsing the CIT(A)'s approach; Revenue Grounds No.2 and 2.1 were accordingly dismissed.
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