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    <title>2022 (7) TMI 1507 - ITAT DELHI</title>
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    <description>Receipts from remedial work on an oil well were held to be taxable on a presumptive basis under section 44BB because the services were directly and inextricably connected with prospecting for, or extraction or production of, mineral oil. Applying the pith and substance test and the wide meaning of &quot;in connection with,&quot; the work, including retrieval and installation of the XMT, fell within the oil exploration activity covered by section 44BB. The receipts were therefore not assessable as fees for technical services under section 9(1)(vii) or section 44DA, and the fact that the assessee was a second-line contractor did not exclude section 44BB.</description>
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      <title>2022 (7) TMI 1507 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=312384</link>
      <description>Receipts from remedial work on an oil well were held to be taxable on a presumptive basis under section 44BB because the services were directly and inextricably connected with prospecting for, or extraction or production of, mineral oil. Applying the pith and substance test and the wide meaning of &quot;in connection with,&quot; the work, including retrieval and installation of the XMT, fell within the oil exploration activity covered by section 44BB. The receipts were therefore not assessable as fees for technical services under section 9(1)(vii) or section 44DA, and the fact that the assessee was a second-line contractor did not exclude section 44BB.</description>
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