https://www.taxtmi.com/caselaws?id=259942 A non-resident leasing a drilling rig for mineral oil operations satisfied the conditions of section 44BB because the decisive factor was deployment of the plant or machinery in prospecting for or extraction of mineral oil. The arrangement being routed through a contractor or sub-contractor did not exclude section 44BB treatment, as that provision does not distinguish between direct and indirect supply where the rig is used for the relevant oil activity. The receipt was therefore assessable on the deemed profit basis under section 44BB, with the existence of a permanent establishment and effective connection in India also supporting that treatment, and it was not taxable as royalty. en-us Fri, 22 May 2015 00:00:00 +0530 Wed, 27 May 2015 06:44:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=259942 A non-resident leasing a drilling rig for mineral oil operations satisfied the conditions of section 44BB because the decisive factor was deployment of the plant or machinery in prospecting for or extraction of mineral oil. The arrangement being routed through a contractor or sub-contractor did not exclude section 44BB treatment, as that provision does not distinguish between direct and indirect supply where the rig is used for the relevant oil activity. The receipt was therefore assessable on the deemed profit basis under section 44BB, with the existence of a permanent establishment and effective connection in India also supporting that treatment, and it was not taxable as royalty. Case-Laws Income Tax Fri, 22 May 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=259942