https://www.taxtmi.com/caselaws?id=786996 Assessing Officer's issuance of a provisional withholding certificate treating receipts as royalty/fees for technical services was set aside for lack of reasoned application of the legal tests distinguishing Section 44BB-style income from Section 44DA-style FTS/royalty; the Court required the AO to assess whether receipts in substance fell within the contractual and definitional exclusions applicable to seismic survey services and to address binding precedent and prior consistent treatment before directing withholding. Outcome: certificate directing withholding at the higher rate was quashed and the matter remanded for fresh, reasoned consideration within three weeks. en-us Fri, 20 Feb 2026 00:00:00 +0530 Tue, 24 Feb 2026 08:36:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786996 Assessing Officer's issuance of a provisional withholding certificate treating receipts as royalty/fees for technical services was set aside for lack of reasoned application of the legal tests distinguishing Section 44BB-style income from Section 44DA-style FTS/royalty; the Court required the AO to assess whether receipts in substance fell within the contractual and definitional exclusions applicable to seismic survey services and to address binding precedent and prior consistent treatment before directing withholding. Outcome: certificate directing withholding at the higher rate was quashed and the matter remanded for fresh, reasoned consideration within three weeks. Case-Laws Income Tax Fri, 20 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786996