https://www.taxtmi.com/caselaws?id=781332 Receipts from software, support services, training, and allied oilfield activities were treated as falling within the special presumptive regime for oilfield services because their pith and substance showed a direct, inextricable connection with prospecting for, extraction of, or production of mineral oil; they were therefore taxable under section 44BB and not as fees for technical services or royalty under the general charging provisions. Interest on income-tax refund was separately governed by the India-USA DTAA and was taxable at the treaty rate applied under Article 11. The Revenue's challenge failed on both issues, and the assessee's treatment was upheld. en-us Wed, 10 Sep 2025 00:00:00 +0530 Sat, 08 Nov 2025 13:55:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781332 Receipts from software, support services, training, and allied oilfield activities were treated as falling within the special presumptive regime for oilfield services because their pith and substance showed a direct, inextricable connection with prospecting for, extraction of, or production of mineral oil; they were therefore taxable under section 44BB and not as fees for technical services or royalty under the general charging provisions. Interest on income-tax refund was separately governed by the India-USA DTAA and was taxable at the treaty rate applied under Article 11. The Revenue's challenge failed on both issues, and the assessee's treatment was upheld. Case-Laws Income Tax Wed, 10 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781332