https://www.taxtmi.com/caselaws?id=10513 Section 44BB operates as a self-contained computation code for deemed profits from oil exploration activities of a non-resident, and section 195A does not function as a charging provision. Tax deduction at source therefore does not alter the character of the receipt or justify multiple-stage grossing up of deemed income. The benefit arising where tax is borne by the payer is to be valued on a single-stage basis, and the Revenue's attempt to enlarge deemed profits was rejected. en-us Wed, 29 Jun 2005 00:00:00 +0530 Fri, 17 Jul 2009 10:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=10513 Section 44BB operates as a self-contained computation code for deemed profits from oil exploration activities of a non-resident, and section 195A does not function as a charging provision. Tax deduction at source therefore does not alter the character of the receipt or justify multiple-stage grossing up of deemed income. The benefit arising where tax is borne by the payer is to be valued on a single-stage basis, and the Revenue's attempt to enlarge deemed profits was rejected. Case-Laws Income Tax Wed, 29 Jun 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=10513