https://www.taxtmi.com/caselaws?id=65498 The Tribunal dismissed the Revenue's appeal and allowed the assessee's appeal. It was held that reimbursements for equipment, communication charges, and dry fruits are not includible in gross receipts under Section 44BB due to their lack of connection with oil extraction activities and absence of a profit element. Additionally, interest on tax refunds should be taxed at 10% under Article 12(2) of the DTAA with France as it is not connected with the Permanent Establishment in India. en-us Fri, 22 Feb 2008 00:00:00 +0530 Sat, 21 Jul 2012 17:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=65498 The Tribunal dismissed the Revenue's appeal and allowed the assessee's appeal. It was held that reimbursements for equipment, communication charges, and dry fruits are not includible in gross receipts under Section 44BB due to their lack of connection with oil extraction activities and absence of a profit element. Additionally, interest on tax refunds should be taxed at 10% under Article 12(2) of the DTAA with France as it is not connected with the Permanent Establishment in India. Case-Laws Income Tax Fri, 22 Feb 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=65498