Tug and barge use for transporting compressor module linked to contract execution; assess payments u/s 44BB IT Act.

Income assessable under Section 44BB or not? - authorities were not justified in arriving at the conclusion that the use of the tugs and barges was in the nature of a mere transportation facility. On facts, respondent no.1, in terms, recorded that tugs were hired by the petitioner to transport the Compressor module from the yard to the offshore platform. The said compressor module, as it emerges from the record, was an integral part of the execution of the contract by the petitioner. - The payments made by the petitioner to the non-resident assessess in the execution of the contract with ONGC is properly assessable under the provisions on Section 44BB of the Act, 1961. - HC .....

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