https://www.taxtmi.com/caselaws?id=465042 ITAT Dehradun held that the receipts of the non-resident assessee, a Hong Kong tax resident with a project office constituting a PE in India, are chargeable to tax only under s.44BB and not under s.44DA, as they relate to services in connection with prospecting, extraction or production of mineral oils. It further held that service tax reimbursed by the service recipient does not form part of the gross receipts for computing presumptive income under s.44BB. On the separate issue of taxability of interest on income tax refund under s.244A, the Tribunal held that such interest to a foreign company is taxable at the maximum marginal rate, rejecting applicability of s.115A. en-us Fri, 15 Sep 2023 00:00:00 +0530 Tue, 02 Dec 2025 21:24:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465042 ITAT Dehradun held that the receipts of the non-resident assessee, a Hong Kong tax resident with a project office constituting a PE in India, are chargeable to tax only under s.44BB and not under s.44DA, as they relate to services in connection with prospecting, extraction or production of mineral oils. It further held that service tax reimbursed by the service recipient does not form part of the gross receipts for computing presumptive income under s.44BB. On the separate issue of taxability of interest on income tax refund under s.244A, the Tribunal held that such interest to a foreign company is taxable at the maximum marginal rate, rejecting applicability of s.115A. Case-Laws Income Tax Fri, 15 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465042