https://www.taxtmi.com/caselaws?id=433605 Receipts from hiring rigs to an Indian entity for drilling and exploration of mineral oils fall within the special presumptive scheme in section 44BB, because that provision covers a non-resident supplying plant or machinery on hire for prospecting, extraction or production of mineral oils and applies on gross receipts without requiring a permanent establishment in India. The same receipts are excluded from the royalty definition in section 9(1)(vi) by the statutory carve-out in Explanation 2, clause (iva), so they cannot be taxed as royalty merely because the equipment was leased for oil exploration. en-us Wed, 01 Feb 2023 00:00:00 +0530 Sat, 04 Feb 2023 08:43:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=433605 Receipts from hiring rigs to an Indian entity for drilling and exploration of mineral oils fall within the special presumptive scheme in section 44BB, because that provision covers a non-resident supplying plant or machinery on hire for prospecting, extraction or production of mineral oils and applies on gross receipts without requiring a permanent establishment in India. The same receipts are excluded from the royalty definition in section 9(1)(vi) by the statutory carve-out in Explanation 2, clause (iva), so they cannot be taxed as royalty merely because the equipment was leased for oil exploration. Case-Laws Income Tax Wed, 01 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=433605