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In RE : Corpro Systems Limited, UK

2016 (9) TMI 343 - AUTHORITY FOR ADVANCE RULINGS NEW DELHI

Taxability of considerations received under the Contract - Held that:- All the considerations received under the Contract whether as a Contractor or as a Sub-Contractor by applicant Corpro would be taxable under Section 44BB of the Income Tax Act. - The answer to the Question No. 2 is that the withholding of the tax would be in the spirit of Section 44BB, hence, we dispose of all the 4 applications. - A.A.R. No.1131 & 1133 of 2011 & A.A.R. No. 1415 & 1416 of 2012 - Dated:- 4-4-2016 - V.S. Si .....

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Systems Limited, UK. We shall use the facts in Application No. 1131 only as all the facts about the activity of the applicant are similar, if not identical. It is stated as it is the claim of the applicant company that it is a tax resident of United Kingdom ( UK ) and is engaged in rendering coring services/providing coring equipments/ and other associated services to global oil & gas companies. It is apparent from the further facts that one Schlumberger Asia Services Limited ( SASL ), Schlu .....

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. It is further explained that coring services generally include the removal of sample formation material from a wellbore for further analysis of the said samples. These samples are required to be taken in an undamaged and physically unaltered state. This formation material might be solid rock, friable rock, conglomerates, unconsolidated sands, coal shale s, gumbos, or clays. These samples are then provided to clients for analysis to examine the presence of oil in the block for exploration purpo .....

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Section 44BB. The applicant also points out that the mineral oil includes petroleum and natural gas as per the Explanation to Section. The applicant also points out that the term plant includes ships, aircraft, vehicles, drilling units, scientific apparatus and equipments, used for the purpose of the said business. The facts in the other three applications are similar, if not identical to the above stated facts. There is no dispute over the nature of service provided by the applicant in all the .....

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stion involved and after referring to a circular of the Department No. 1862 dated 22.10.1990 has come to the conclusion that the consideration for the mining services will not be treated as Fees for Technical Services for the purpose of Explanation-2 to Section 9(1)(vii). 3. Further referring to the various services which were divided amongst 8 Heads, the Hon ble Apex Court has named as many as 44 services in all. The learned counsel points out that out of these 44 services activity at Sl. No. 8 .....

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