Tribunal held that since neither Assessing Officer nor DRP had examined applicability of section 44BB by looking into whether pith and substance of each of contract/agreement entered by assessee was inextricably connected with prospecting, extraction or production of mineral oil, matter was to be remanded to pass an order afresh after examining each of contract/agreement . ( AY. 2015-16)
Maritime Vanguard Pte. Ltd. v. ACIT (IT) (2020) 182 ITD 339 (Mum.)(Trib.)
S. 44BB : Mineral oils-Computation-Royalty-Substance of contract-Matter remanded-DTAA-India-Singapore. [S. 9(1)(vi), Art. 5, 12]