https://www.taxtmi.com/caselaws?id=256899 Rental receipts from seismic survey vessels hired to a non-resident charterer for geophysical prospection and mineral oil exploration are covered by the presumptive regime in section 44BB, because the vessels were supplied on hire for operations integrally connected with prospecting for, or extraction or production of, mineral oils. The absence of a direct contract with the oil exploration company did not exclude the taxpayer from section 44BB, and the arrangement was not treated in substance as a mere time-charter. Once section 44BB applied, the receipts were not taxable as royalty under section 9(1)(vi) or Article 13 of the India-France DTAA. en-us Tue, 17 Feb 2015 00:00:00 +0530 Tue, 24 Feb 2015 12:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=256899 Rental receipts from seismic survey vessels hired to a non-resident charterer for geophysical prospection and mineral oil exploration are covered by the presumptive regime in section 44BB, because the vessels were supplied on hire for operations integrally connected with prospecting for, or extraction or production of, mineral oils. The absence of a direct contract with the oil exploration company did not exclude the taxpayer from section 44BB, and the arrangement was not treated in substance as a mere time-charter. Once section 44BB applied, the receipts were not taxable as royalty under section 9(1)(vi) or Article 13 of the India-France DTAA. Case-Laws Income Tax Tue, 17 Feb 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=256899