Assessee, a Singapore based company, which is  engaged in providing services and facilities relating to exploration and exploitation of mineral oil and natural gas.  During year, it had taken rigs on hire as bareboat from DDPL and paid bareboat charges.  It had offered income under section 44BB on presumptive basis.  Tribunal held that  payment made to DDPL were its business income and in absence of PE in India, assessee was not liable to deduct any tax in India under section 195 and, therefore, disallowance made under section 40(a)(i) is to be deleted.  (AY. 2021-22)