https://www.taxtmi.com/caselaws?id=261129 An exemption notification under Section 24AA of the Companies (Profits) Surtax Act had to be read strictly by its plain language. The provision created two distinct categories of foreign companies: clause (a) covered agreements for direct association or participation in mineral oil business, while clause (b) covered companies providing services or facilities in connection with that business. Because the notification expressly extended relief only to the clause (a) category and did not include clause (b), its scope could not be enlarged by relying on legislative intent. The exemption therefore remained confined to direct participation agreements, and service contracts falling within clause (b) were outside the notified benefit. en-us Wed, 01 Jul 2015 00:00:00 +0530 Wed, 04 Oct 2017 15:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=261129 An exemption notification under Section 24AA of the Companies (Profits) Surtax Act had to be read strictly by its plain language. The provision created two distinct categories of foreign companies: clause (a) covered agreements for direct association or participation in mineral oil business, while clause (b) covered companies providing services or facilities in connection with that business. Because the notification expressly extended relief only to the clause (a) category and did not include clause (b), its scope could not be enlarged by relying on legislative intent. The exemption therefore remained confined to direct participation agreements, and service contracts falling within clause (b) were outside the notified benefit. Case-Laws Income Tax Wed, 01 Jul 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=261129