https://www.taxtmi.com/caselaws?id=178775 Helicopter support receipts under a composite contract for mineral oil exploration were held to fall under section 44BB, not section 44BBA, because the true commercial character of the arrangement was the provision of services, personnel, equipment and facilities connected with prospecting for or production of mineral oils. The receipts were therefore assessable under the special presumptive regime for mineral-oil related services. For article 15(2)(c) of the India-Australia DTAA, remuneration paid to Australian resident employees was treated as deductible in computing the taxable profits of the Indian permanent establishment, since deductible was given a substantive commercial meaning and the contrary view would defeat the treaty's intended tax allocation. en-us Wed, 30 Apr 1997 00:00:00 +0530 Fri, 12 Feb 2016 13:03:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=178775 Helicopter support receipts under a composite contract for mineral oil exploration were held to fall under section 44BB, not section 44BBA, because the true commercial character of the arrangement was the provision of services, personnel, equipment and facilities connected with prospecting for or production of mineral oils. The receipts were therefore assessable under the special presumptive regime for mineral-oil related services. For article 15(2)(c) of the India-Australia DTAA, remuneration paid to Australian resident employees was treated as deductible in computing the taxable profits of the Indian permanent establishment, since deductible was given a substantive commercial meaning and the contrary view would defeat the treaty's intended tax allocation. Case-Laws Income Tax Wed, 30 Apr 1997 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=178775