https://www.taxtmi.com/caselaws?id=204762 Offshore logistics and support services connected with oil exploration, including cargo transport, standby, rescue and surveillance operations, were treated as income from prospecting for or extraction of mineral oils and therefore fell within the presumptive regime of section 44BB; they were not characterised as fees for technical services or royalty. After the applicant became a Norwegian tax resident, the India-Norway DTAA did not give exclusive taxing rights to Norway, because Article 23(4) still permitted taxation in India on a restricted presumptive basis. Amounts collected as service tax were excluded from the income base, as service tax is a statutory levy and not consideration for services. en-us Mon, 25 Jul 2011 00:00:00 +0530 Tue, 26 Apr 2016 16:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=204762 Offshore logistics and support services connected with oil exploration, including cargo transport, standby, rescue and surveillance operations, were treated as income from prospecting for or extraction of mineral oils and therefore fell within the presumptive regime of section 44BB; they were not characterised as fees for technical services or royalty. After the applicant became a Norwegian tax resident, the India-Norway DTAA did not give exclusive taxing rights to Norway, because Article 23(4) still permitted taxation in India on a restricted presumptive basis. Amounts collected as service tax were excluded from the income base, as service tax is a statutory levy and not consideration for services. Case-Laws Income Tax Mon, 25 Jul 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=204762