https://www.taxtmi.com/caselaws?id=358136 Mobilisation charges, reimbursement of expenses and demobilisation receipts were held includible in the presumptive gross receipts base under section 44BB because they were intrinsically linked to rig mobilisation and demobilisation; the issue was decided for the Revenue. Interest on income-tax refund was treated differently, as it was not effectively connected with the permanent establishment under either the asset test or the activity test, so it fell within Article XI of the Indo-US treaty and was taxable at the treaty rate; this issue was decided for the assessee. The overall result was a mixed outcome. en-us Wed, 31 Jan 2018 00:00:00 +0530 Fri, 06 Apr 2018 07:46:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=358136 Mobilisation charges, reimbursement of expenses and demobilisation receipts were held includible in the presumptive gross receipts base under section 44BB because they were intrinsically linked to rig mobilisation and demobilisation; the issue was decided for the Revenue. Interest on income-tax refund was treated differently, as it was not effectively connected with the permanent establishment under either the asset test or the activity test, so it fell within Article XI of the Indo-US treaty and was taxable at the treaty rate; this issue was decided for the assessee. The overall result was a mixed outcome. Case-Laws Income Tax Wed, 31 Jan 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=358136