https://www.taxtmi.com/caselaws?id=65500 Receipts from seismic data processing and Geolog software training were treated as falling within section 44BB for services connected with mineral oil operations, rather than as separate royalty or fees for technical services. For the seismic processing income, the treaty article on technical services did not apply because the services did not make available technical knowledge; the receipts therefore remained business profits, taxable in India only if the recipient had a permanent establishment, which was absent. For the training services, the specific oil-and-gas provision prevailed over the general technical services and royalty provisions. The departmental challenge failed and the assessee's treatment was sustained. en-us Fri, 27 Jun 2008 00:00:00 +0530 Sun, 10 Dec 2023 18:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=65500 Receipts from seismic data processing and Geolog software training were treated as falling within section 44BB for services connected with mineral oil operations, rather than as separate royalty or fees for technical services. For the seismic processing income, the treaty article on technical services did not apply because the services did not make available technical knowledge; the receipts therefore remained business profits, taxable in India only if the recipient had a permanent establishment, which was absent. For the training services, the specific oil-and-gas provision prevailed over the general technical services and royalty provisions. The departmental challenge failed and the assessee's treatment was sustained. Case-Laws Income Tax Fri, 27 Jun 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=65500