https://www.taxtmi.com/caselaws?id=459492 Receipts from hiring or leasing rigs to an Indian entity for drilling and exploration of mineral oils were held to fall under the special presumptive regime in Section 44BB rather than as royalty under Section 9(1)(vi) of the Income-tax Act. The decisive factor was that the rigs were given on hire or lease for use in mineral oil operations, and Clause (iv-a) of Explanation 2 to Section 9(1)(vi) expressly excludes amounts referable to Section 44BB. On the undisputed facts, the exclusion operated in favour of Section 44BB assessment, and the receipts were not taxable as royalty. en-us Mon, 04 Mar 2024 00:00:00 +0530 Mon, 16 Dec 2024 18:31:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459492 Receipts from hiring or leasing rigs to an Indian entity for drilling and exploration of mineral oils were held to fall under the special presumptive regime in Section 44BB rather than as royalty under Section 9(1)(vi) of the Income-tax Act. The decisive factor was that the rigs were given on hire or lease for use in mineral oil operations, and Clause (iv-a) of Explanation 2 to Section 9(1)(vi) expressly excludes amounts referable to Section 44BB. On the undisputed facts, the exclusion operated in favour of Section 44BB assessment, and the receipts were not taxable as royalty. Case-Laws Income Tax Mon, 04 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459492