https://www.taxtmi.com/caselaws?id=302759 The Tribunal upheld the order of the first appellate authority, dismissing the revenue's appeals regarding the taxation of payments made by ONGC to non-resident companies for services related to mineral oil prospecting. It held that the payments were assessable under section 44BB of the Income Tax Act, not section 44D, based on the contracts' connection to mineral oil activities. The Tribunal affirmed that the services fell under section 44BB, not section 9(1)(vii), emphasizing the dominant purpose of the contracts in mineral oil prospecting. Additionally, it clarified the retrospective application of the proviso to section 44DA, aligning with previous judgments and maintaining the tax assessment under section 44BB. en-us Mon, 16 May 2016 00:00:00 +0530 Fri, 17 Jun 2022 09:34:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=302759 The Tribunal upheld the order of the first appellate authority, dismissing the revenue's appeals regarding the taxation of payments made by ONGC to non-resident companies for services related to mineral oil prospecting. It held that the payments were assessable under section 44BB of the Income Tax Act, not section 44D, based on the contracts' connection to mineral oil activities. The Tribunal affirmed that the services fell under section 44BB, not section 9(1)(vii), emphasizing the dominant purpose of the contracts in mineral oil prospecting. Additionally, it clarified the retrospective application of the proviso to section 44DA, aligning with previous judgments and maintaining the tax assessment under section 44BB. Case-Laws Income Tax Mon, 16 May 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=302759