https://www.taxtmi.com/caselaws?id=261130 SC held that payments made by a national oil exploration company to non-resident assessees/foreign companies for services connected with prospecting, extraction or production of mineral oil are taxable under Section 44BB, not as "fees for technical services" under Section 44D read with Explanation 2 to Section 9(1)(vii). The Court found the pith and substance and dominant purpose of the contracts to be inextricably linked with mineral oil operations, with any technical work being merely ancillary. Consequently, SC set aside the HC orders and restored the Appellate Commissioner and Tribunal's decisions, ruling in favour of the assessees. en-us Wed, 01 Jul 2015 00:00:00 +0530 Tue, 02 Dec 2025 15:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=261130 SC held that payments made by a national oil exploration company to non-resident assessees/foreign companies for services connected with prospecting, extraction or production of mineral oil are taxable under Section 44BB, not as "fees for technical services" under Section 44D read with Explanation 2 to Section 9(1)(vii). The Court found the pith and substance and dominant purpose of the contracts to be inextricably linked with mineral oil operations, with any technical work being merely ancillary. Consequently, SC set aside the HC orders and restored the Appellate Commissioner and Tribunal's decisions, ruling in favour of the assessees. Case-Laws Income Tax Wed, 01 Jul 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=261130