2016 (11) TMI 739

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....activity includes 2D/3D seismic data acquisition in shallow water and transition zone. It is also engaged in study of earth's structure to identify existence of hydrocarbon which assists oil companies in identifying locations for drilling and exploring oil/hydrocarbons. According to the applicant, this is generally referred as seismic study. 3. The applicant has entered into a Contract No.MR/WOB/MM/SC/3D (OBC)/19/2013/P968L13002/EB-2184/9010019008 dated 24th December, 2013 with Oil & Natural Gas Corporation Limited ('ONGC') for hiring of services for 3D OBC Seismic Data Acquisition & Processing in Sector-II: Palk Bay S/W Offshore-PML area & coastal TZ in Cauvery Basin in East Cost during field season 2013-14. 4. On the bas....

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....anything to take any other view of the matter, there can be no dispute that the activities of the applicant are very much covered in the language of Section 44BB. Section 44BB is as follows:- '44BB. Special provision for computing profits and gains in connection with the business of exploration, etc. of mineral oils. 4 (1) Notwithstanding anything to the contrary contained in sections 28 to 41 and sections 43 and 43A, in the case of an assessee being a non-resident, engaged in the business of providing services or facilities in connection with, or supplying plant and machinery on hire used, or to be used, in the prospecting for, or extraction or production of, mineral oils, a sum equal to ten per cent of the aggregate of the amounts ....