Seismic survey vessel income at high sea is taxable in India u/s 44BB; withholding tax required on payments.

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....Income accrued in India - permanent establishment (PE) - Withholding of tax in India - vessel engaged in seismic survey at high sea - The sum paid by the applicant to the vessel providing companies (VPCs) under global usage under bareboat charter (BBC) agreements is deemed to accrue and arise in India and is liable to tax in India under the Income-tax Act and, therefore, subject to withholding tax in India. - The income liable to tax is to be assessed as business income under the provisions of section 44BB of the Act. - AAR....