https://www.taxtmi.com/caselaws?id=437134 Receipts from installation and commissioning services, hire of tools and equipment, and repair services directly linked to prospecting, exploration and extraction of mineral oil were held taxable under section 44BB and not as fees for technical services, because they were inextricably connected with mineral oil operations. Receipts from business support services to the Indian subsidiary were not fees for technical services under the India-Singapore DTAA, as the services did not satisfy the make available requirement in Article 12(4)(b). The reimbursement addition was partly deleted and partly remanded for fresh verification due to incomplete supporting records. en-us Fri, 24 Mar 2023 00:00:00 +0530 Fri, 28 Apr 2023 14:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=437134 Receipts from installation and commissioning services, hire of tools and equipment, and repair services directly linked to prospecting, exploration and extraction of mineral oil were held taxable under section 44BB and not as fees for technical services, because they were inextricably connected with mineral oil operations. Receipts from business support services to the Indian subsidiary were not fees for technical services under the India-Singapore DTAA, as the services did not satisfy the make available requirement in Article 12(4)(b). The reimbursement addition was partly deleted and partly remanded for fresh verification due to incomplete supporting records. Case-Laws Income Tax Fri, 24 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=437134