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Seismic Survey Vessels for Oil Prospecting Taxed u/s 44BB of Income Tax Act, Income Source in India.

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....Income accrue or arise, or deemed to accrue or arise in India - It was admitted that the applicant conducts seismic surveys offshore for which it requires seismic vessels and agreements were made with VPCs for providing such vessels. It was further admitted that provision of such vessels on hire to be used in prospecting of mineral oil is covered u/s 44BB. - the place where the vessels are deployed for operation would be deemed to be the source of such business income. - AAR....