https://www.taxtmi.com/caselaws?id=801318 Payments to non-resident service providers directly and inextricably connected with mineral-oil prospecting, extraction or production fall within the presumptive regime under Section 44BB. The mining-project exclusion from fees for technical services applies where the pith and substance of the agreement establishes that connection. Section 44BB consequently prevails over the general fees-for-technical-services computation mechanism under Section 44DA for qualifying contractual services. Tax deducted at the rate applicable to Section 44BB payments is therefore correct, and the payer is not an assessee in default on that basis. en-us Mon, 17 Aug 2026 00:00:00 +0530 Mon, 19 Oct 2026 07:01:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801318 Payments to non-resident service providers directly and inextricably connected with mineral-oil prospecting, extraction or production fall within the presumptive regime under Section 44BB. The mining-project exclusion from fees for technical services applies where the pith and substance of the agreement establishes that connection. Section 44BB consequently prevails over the general fees-for-technical-services computation mechanism under Section 44DA for qualifying contractual services. Tax deducted at the rate applicable to Section 44BB payments is therefore correct, and the payer is not an assessee in default on that basis. Case-Laws Income Tax Mon, 17 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801318