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    <description>Services connected with seismic data processing, field development consultancy, and assistance in oil and gas operations were treated as integrally connected with prospecting for, exploration of, and production of mineral oils. Applying the pith-and-substance test and the dominant purpose of the contracts, the receipts were brought within the presumptive regime under section 44BB of the Income-tax Act, 1961 rather than characterised as fees for technical services under section 9(1)(vii) read with section 44DA and section 115A. The analysis followed the settled position already applied in the assessee&#039;s own case, and the receipts were assessed under section 44BB.</description>
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