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2003 (9) TMI 65 - HC - Income TaxSection 44BB versus Section 195A- non-resident - profits and gains in connection with the business of oil exploration – section 44BB provides both for chargeability of tax and computation. Therefore, it is a complete code by itself. Section 44BB imposes tax on notional income and that notional income has to be computed in accordance with section 44BB. Therefore, there is no need to refer to section 28(iv) -Section 195A comes under Chapter XVII which deals with collection and recovery of tax whereas section 44BB comes under Chapter IV which deals with computation of business income. Therefore, section 195A will not assist the Department in applying the concept of multiple stage grossing up of income to the profits derived by the NRC from oil exploration falling under section 44BB - Tribunal is right in holding that multiple grossing up of income was permissible
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