Assessee-company, incorporated in France, entered into contract with RIL for providing services in connection with mining activity. Dismissing the appeal of the Reveenue  the Court held that   payments received by assessee under said contract for providing mining activity were not chargeable to tax as fees for technical services under Explanation 2 to section 9(1)(vii) but more appropriately assessable under section 44BB.  (AY. 2010-11)