Cementing services under contracts not classified as technical fees; Section 44BB applies, not Section 44DA, per IT Act.

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....Consideration for the services under the contracts for provision of cementing services fall under the exclusion and doesn’t qualify as fees for technical services as per explanation to section 9(1)(vii) and in any case, the provisions of section 44BB being more specific, shall be applicable and provisions of section 44DA are not applicable in the instant case. - AT....