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Income from the services rendered in connection with providing drilling rigs/drilling services to ‘Cairn’ in India are in the nature of services and facilities in connection with, or supplying plant and machinery on hire which are used in prospecting for extraction or production of mineral oil and the provisions of section 44BB would apply and the income would be taxable accordingly and not as fee for technical services either u/s 44DA or section 115A - Tri

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