https://www.taxtmi.com/caselaws?id=358349 Consideration from geophysical and seismic survey operations for ONGC was not taxable as fees for technical services or royalty because no right to use the vessels or equipment was transferred and the receipts did not fit either description. The applicant was held to have a permanent establishment in India under Article 5(1) of the India-UAE DTAA, as the vessels and equipment formed a fixed place through which the business was carried on in a defined area; the special service-PE clause did not apply. As the income was taxable as business income, it was required to be computed under section 44BB for mineral oil exploration activities. en-us Wed, 28 Mar 2018 00:00:00 +0530 Thu, 31 May 2018 13:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=358349 Consideration from geophysical and seismic survey operations for ONGC was not taxable as fees for technical services or royalty because no right to use the vessels or equipment was transferred and the receipts did not fit either description. The applicant was held to have a permanent establishment in India under Article 5(1) of the India-UAE DTAA, as the vessels and equipment formed a fixed place through which the business was carried on in a defined area; the special service-PE clause did not apply. As the income was taxable as business income, it was required to be computed under section 44BB for mineral oil exploration activities. Case-Laws Income Tax Wed, 28 Mar 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=358349