Payments received under contracts were not chargeable to tax as fees for technical services. Assessable on a presumptive basis under section 44BB of the Act. (AY. 2011-12) (AY. 2010-11)
Dy. CIT(IT) v. SBS Marine Ltd. (2021) 189 ITD 621 (Dehradun) (Trib.) Dy. CIT(IT) v. Swiber Offshore Marine Pte. Ltd. (2021) 189 ITD 616 (Dehradun)(Trib.)
S. 44BB : Mineral oils-Computation-Non-Residents-Vessels-Services in connection with prospecting, extraction or production of mineral oils-Cannot be assessed as fees for technical services. [S. 9(1)(vii), 44D]