Held that the assessee, as a non-resident, is  given the benefit of the special rate of tax per section 44BB, the legislative intent was only to tax the assessee at 10 per cent. of the amount paid or payable to the assessee, received on account of the business activity of the assessee. The word amount could not be interpreted to mean the Goods and Services Tax/Service Tax, which was collected by the assessee from its customers and paid to the Government. Thus, the circulars could not be interpreted differently to include Goods and Services Tax/Service Tax while computing the profit and gains of a non-resident, engaged in the business of exploration, etc., of mineral oils. Addition is deleted. (AY. 2021-22)