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    <title>2016 (5) TMI 1341 - AUTHORITY FOR ADVANCE RULINGS</title>
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    <description>Section 44BB was construed as a self-contained presumptive regime for non-residents providing services or facilities in connection with the prospecting for, or extraction or production of, mineral oils, and the expression &quot;mineral oil&quot; was read broadly to include crude oil and products derived from petroleum. On that basis, receipts under the contract for installation of SPM systems, offshore and onshore pipelines, and associated facilities at a refinery were held to be covered by section 44BB, and the entire consideration was chargeable under that provision rather than being treated outside it or under fee-for-technical-services provisions. The Authority also noted that earlier rulings on different contractual structures did not alter this result.</description>
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      <title>2016 (5) TMI 1341 - AUTHORITY FOR ADVANCE RULINGS</title>
      <link>https://www.taxtmi.com/caselaws?id=191441</link>
      <description>Section 44BB was construed as a self-contained presumptive regime for non-residents providing services or facilities in connection with the prospecting for, or extraction or production of, mineral oils, and the expression &quot;mineral oil&quot; was read broadly to include crude oil and products derived from petroleum. On that basis, receipts under the contract for installation of SPM systems, offshore and onshore pipelines, and associated facilities at a refinery were held to be covered by section 44BB, and the entire consideration was chargeable under that provision rather than being treated outside it or under fee-for-technical-services provisions. The Authority also noted that earlier rulings on different contractual structures did not alter this result.</description>
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