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2016 (11) TMI 739 - AUTHORITY FOR ADVANCE RULINGS NEW DELHI

2016 (11) TMI 739 - AUTHORITY FOR ADVANCE RULINGS NEW DELHI - TMI - Hiring of services for 3D OBC Seismic Data Acquisition & Processing in Sector-II - taxability in India in accordance with section 44BB(1) - Held that:- As decided in OIL & NATURAL GAS CORPORATION LIMITED Versus COMMISSIONER OF INCOME TAX & ANOTHER [2015 (7) TMI 91 - SUPREME COURT] the works carried out by the applicant are liable to be covered under the provisions, of Section 44BB of Income Tax Act. - We have taken the same .....

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Taranpreet Singh, FCA For The Department : S.S. Negi, JCIT-DR(AAR), ND RULING Justice V.S. Sirpurkar, Chairman - The applicant is a Russian company incorporated under the laws of Russia and is a tax resident of Russia. 2. The applicant is engaged in the business of rendering geophysical services to oil and gas exploration industry. Its core business activity includes 2D/3D seismic data acquisition in shallow water and transition zone. It is also engaged in study of earth's structure to ident .....

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Offshore-PML area & coastal TZ in Cauvery Basin in East Cost during field season 2013-14. 4. On the basis of this, the applicant has one question as under:- "Whether revenues earned by the Applicant under contract No. MRA/WOB/MMSC/3D(OBC)/19/2013/P968L13002/EB-2184/90 100 19008 dated 24th December, 2013 with Oil & Natural Gas Corporation Limited ('ONGC') for hiring of services for 3D OBC Seismic Data Acquisition & Processing in Sector-II are taxable in India in accordan .....

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y of dated 31.5.2016. They have mentioned in the reply of dated 31.5.2016 that this matter is covered by the Apex Court's judgment dated 1.7.2015 in ONGC Ltd. v. CIT [2015] 376 ITR 306. They have also indicated in their reply that the Apex Court has held that the works carried out by the applicant are liable to be covered under the provisions, of Section 44BBof Income Tax Act. 7. In short, the Department seems to have agreed with the contention raised by the applicant that the activities of .....

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tions 28 to 41 and sections 43 and 43A, in the case of an assessee being a non-resident, engaged in the business of providing services or facilities in connection with, or supplying plant and machinery on hire used, or to be used, in the prospecting for, or extraction or production of, mineral oils, a sum equal to ten per cent of the aggregate of the amounts specified in sub-section (2) shall be deemed to be the profits and gains of such business chargeable to tax under the head "Profits an .....

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of services and facilities in connection with, or supply of plant and machinery on hire used, or to be used, in the prospecting for, or extraction or production of, mineral oils in India; and (b) the amount received or deemed to be received in India by or on behalf of the assessee on account of the provision of services and facilities in connection with, or supply of plant and machinery on hire used, or to be used, in the prospecting for, or extraction or production of, mineral oils outside Ind .....

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