AAR held that payment made for providing off shore seismic data acquisition and processing services to ONGC in Bombay High. Payment to non-resident companies is not royalty . Amount taxable under section 44BB of the Act
Seabird Exploration Fz Llc, In Re (2021) 431 ITR 503 / 198 DTR 313/ 319 CTR 225 (AAR)
S. 44BB : Mineral oils – Computation -Providing off shore seismic data acquisition and processing services to ONGC in Bombay High — Payment to non-resident companies – Not royalty – Taxable under section 44BB .[ S.9(1)(vi)]