Transocean Offshore International Venture Ltd. v. Dy.CIT(IT) (2022) 94 ITR 59 (SN) (Dehradun)(Trib.)

S. 44BB : Mineral oils-Computation-Presumptive tax-Non-Resident-Prospecting for, or extraction or production of mineral oils-Receipt on account of reimbursement of expenses-Amounts received towards mobilization advance-Includible in gross receipts-Service tax receipts-Excludible.

Held that receipt on account of reimbursement of expenses was includible in the gross receipts under section 44BB. Followed CIT v. Halliburton Offshore Services Inc. (2008) 300 ITR 265  (Uttarakhand)(HC)   That the amounts received towards mobilization were includible in the total amount received by the assessee against its work. Followed  Sedco Forex International Inc. v. CIT (2008) 299 ITR  238   (Uttarakhand) (HC) (affirmed in (2017) 399 ITR 1 (SC). That the exclusion of service tax receipts from the gross receipts for purposes of section 44BB was proper. (AY. 2013-14)