https://www.taxtmi.com/caselaws?id=778706 Receipts from operating vessels for transportation in aid of offshore exploration activities fell within Article 21(4) of the India-Norway DTAA because the assessee was not itself engaged in exploration or exploitation of the seabed, subsoil or their natural resources. The deeming rule in Article 21(2) and the limitation in Article 21(3) did not apply on the facts, and the treaty specifically covered profits from transporting supplies or personnel and operating tugboats or other auxiliary vessels. As a result, the special treaty provision prevailed over section 44BB of the Income-tax Act, 1961, and the income was taxed under the DTAA rather than under the domestic presumptive regime. en-us Wed, 17 Sep 2025 00:00:00 +0530 Fri, 19 Sep 2025 10:20:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=778706 Receipts from operating vessels for transportation in aid of offshore exploration activities fell within Article 21(4) of the India-Norway DTAA because the assessee was not itself engaged in exploration or exploitation of the seabed, subsoil or their natural resources. The deeming rule in Article 21(2) and the limitation in Article 21(3) did not apply on the facts, and the treaty specifically covered profits from transporting supplies or personnel and operating tugboats or other auxiliary vessels. As a result, the special treaty provision prevailed over section 44BB of the Income-tax Act, 1961, and the income was taxed under the DTAA rather than under the domestic presumptive regime. Case-Laws Income Tax Wed, 17 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=778706