CIT v. Mitchell Drilling International P. Ltd.

380 ITR 130High Court2016#1355 most cited

What is CIT v. Mitchell Drilling International P. Ltd. authority for?

For computing presumptive income under Section 44BB, gross receipts do not include service tax reimbursements received from a client (like ONGC) if such amounts are not payments for services or plant/machinery directly used in the prospecting, extraction, or production of mineral oils.

84

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2025.

Also referred to as

CIT v. Mitchell Drilling International P. Ltd. · 380 ITR 130 · Section 44BB · gross receipts · presumptive income · service tax reimbursement · mineral oils · ONGC · oil exploration services

Sections most often in play

Section 44BBSection 1961Section 44DASection 9(1)(vi)Section 9(1)(vii)Section 143(3)Section 115ASection 115A of the Income Tax Act

Issues it is cited on

section 44dasection 293section 44bbsection 44bsection 44deconomic adjustmentsection 255(4)section 115asection 42far analysissection 92c(2)interest on refund

Judgments citing CIT v. Mitchell Drilling International P. Ltd.

OCEANEERING INTERNATIONAL GMBH,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION) RANGE 3(2)(2), MUMBAI

ITA 6705/MUM/2025[2023-24]Status: DisposedITAT Mumbai12 Dec 2025AY 2023-24

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

For Appellant: Shri A.K. JawadwalaFor Respondent: Shri Krishna Kumar, Sr.DR
Section 143(3)Section 172Section 44B

…rovided by the assessee, which can form part of the gross receipts for the purposes of computation of gross income under Section 44BB(1) read with Section 44BB(2). DIT v. Mitchell Drilling International (P.) Ltd. [2015] 62 taxmann.com 24/234 Taxman 818/[2016] 380 ITR 130 (Delhi). On its literal construction, Section 44BB(2) would only be the amount paid by the ONGC to the assessee on account of (i) provision of services in connection with or (ii) supply of plant and machinery on hire used in, the prospecting, extraction and production of mineral oils. As the amount reimbursed by the ONGC, towards the service tax…

DY. COMMISSISSIONER OF INCOME TAX, DEHRADUN vs. WEATHERFORD OIL TOOLS ME LIMITED, DEHRADUN

In the result, Appeals of the Revenue’s are dismissed

ITA 168/DDN/2024[2016-17]Status: DisposedITAT Dehradun28 Oct 2025AY 2016-17

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 448Section 44BSection 9(1)(vi)Section 9(1)(vii)

…per the provisions of Section 44BB of the Act . 6 . Now, coming to the second issue relating to the service tax, learned AR placed reliance on the decision of the Hon'ble Jurisdiction High Court in the case of CIT vs. Mitchell Drilling International P. Ltd . 380 ITR 130 in support of his contention that the service-tax being statutory levy , should not form part of gross receipts as per provision of Section 44BB of the Act . He further placed reliance on the decision of the coordinate bench in the case of DDIT vs. Sundowner Offshore International (Bermuda) Ltd. ITA 1067/De1/2016 for a similar principle. We find…

DY. COMMISSISSIONER OF INCOME TAX, DEHRADUN vs. WEATHERFORD OIL TOOLS ME LIMITED, MUMBAI

In the result, Appeals of the Revenue’s are dismissed

ITA 167/DDN/2024[2021-22]Status: DisposedITAT Dehradun28 Oct 2025AY 2021-22

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 448Section 44BSection 9(1)(vi)Section 9(1)(vii)

…per the provisions of Section 44BB of the Act . 6 . Now, coming to the second issue relating to the service tax, learned AR placed reliance on the decision of the Hon'ble Jurisdiction High Court in the case of CIT vs. Mitchell Drilling International P. Ltd . 380 ITR 130 in support of his contention that the service-tax being statutory levy , should not form part of gross receipts as per provision of Section 44BB of the Act . He further placed reliance on the decision of the coordinate bench in the case of DDIT vs. Sundowner Offshore International (Bermuda) Ltd. ITA 1067/De1/2016 for a similar principle. We find…

DY. COMMISSISSIONER OF INCOME TAX, DEHRADUN vs. WEATHERFORD OIL TOOLS ME LIMITED, MUMBAI

In the result, Appeals of the Revenue’s are dismissed

ITA 166/DDN/2024[2020-21]Status: DisposedITAT Dehradun28 Oct 2025AY 2020-21

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 448Section 44BSection 9(1)(vi)Section 9(1)(vii)

…per the provisions of Section 44BB of the Act . 6 . Now, coming to the second issue relating to the service tax, learned AR placed reliance on the decision of the Hon'ble Jurisdiction High Court in the case of CIT vs. Mitchell Drilling International P. Ltd . 380 ITR 130 in support of his contention that the service-tax being statutory levy , should not form part of gross receipts as per provision of Section 44BB of the Act . He further placed reliance on the decision of the coordinate bench in the case of DDIT vs. Sundowner Offshore International (Bermuda) Ltd. ITA 1067/De1/2016 for a similar principle. We find…

DY. COMMISSISSIONER OF INCOME TAX, DEHRADUN vs. WEATHERFORD OIL TOOLS ME LIMITED, MUMBAI

In the result, Appeals of the Revenue’s are dismissed

ITA 165/DDN/2024[2019-20]Status: DisposedITAT Dehradun28 Oct 2025AY 2019-20

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 448Section 44BSection 9(1)(vi)Section 9(1)(vii)

…per the provisions of Section 44BB of the Act . 6 . Now, coming to the second issue relating to the service tax, learned AR placed reliance on the decision of the Hon'ble Jurisdiction High Court in the case of CIT vs. Mitchell Drilling International P. Ltd . 380 ITR 130 in support of his contention that the service-tax being statutory levy , should not form part of gross receipts as per provision of Section 44BB of the Act . He further placed reliance on the decision of the coordinate bench in the case of DDIT vs. Sundowner Offshore International (Bermuda) Ltd. ITA 1067/De1/2016 for a similar principle. We find…

DY. COMMISSISSIONER OF INCOME TAX, DEHRADUN vs. WEATHERFORD OIL TOOLS ME LIMITED, MUMBAI

In the result, Appeals of the Revenue's are dismissed

ITA 164/DDN/2024[2018-19]Status: DisposedITAT Dehradun28 Oct 2025AY 2018-19

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalι.Τ.Α. No. 168/Ddn/2024 (A.Y 2016-17) Ι.Τ.Α. Νο. 163/Ddn/2024 (A.Y 2017-18) Ι.Τ.Α. Νο. 164/Ddn/2024 (A.Y 2018-19) Ι.Τ.Α. Νο. 165/Ddn/2024 (A.Y 2019-20) Ι.Τ.Α. No. 166/Ddn/2024 (A.Y 2020-21) Ι.Τ.Α. Νο. 167/Ddn/2024 (A.Y 2021-22) Dy. Commissioner Of Income Vs Weatherford Oil Tools M.E Tax, Aayakar Bhawan, 13-A, Subhash Road, Dehradun, Uttarakhand Limited. 6Th Floor, Vaman Centre, Makwana Road, J. B. Nagar, Mumbai, Maharashtra Pan: Aaacw1524G Appellant Respondent Assessee By Sh. Salil Kapoor, Adv, Sh. Amit Arora, Adv, Sh. Shivamyadav, Adv & Ms. Somya Singh, Adv Revenue By Sh. Mohan Lal Joshi, Sr. Dr Date Of Hearing 09/09/2025 Date Of Pronouncement 28/10/2025 Order Per Yogesh Kumar, U.S. Jm: The Captioned Appeals Are Filed By The Revenue Against The Orders Of Commissioner Of Income Tax (Appeals) Cit(A)-Noida, 2 ('Ld. Cit(A)' For Short), Delhi Dated 31/07/2024 For The Assessment Years2016-17, 2017-18, 2018-19, 2019-20, 2020-21 & 2021-22 Respectively. 2. All The Above Appeals Are Having Identical Issues To Be Decided, Therefore, The Captioned Appeals Filed By The Revenue Were Heard Together & Decided In This Common Order. 2

Section 44BSection 9(1)(vi)Section 9(1)(vii)

…as per the provisions of Section 44BB of the Act . 6. Now, coming to the second issue relating to the service tax, learned AR placed reliance on the decision of the Hon'ble Jurisdiction High Court in the case of CIT vs. Mitchell Drilling International P. Ltd 380 ITR 130 in support of his contention that the service-tax being statutory levy should not form part of gross receipts as per provision of Section 44BB of the Act . He further placed reliance on the decision of the coordinate bench in the case of DDIT vs. Sundowner Offshore International (Bermuda) Ltd. ITA 1067/De1/2016 for a similar principle. We find th…

DY. COMMISSISSIONER OF INCOME TAX, DEHRADUN vs. WEATHERFORD OIL TOOLS ME LIMITED, MUMBAI

In the result, Appeals of the Revenue’s are dismissed

ITA 163/DDN/2024[2017-18]Status: DisposedITAT Dehradun28 Oct 2025AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 448Section 44BSection 9(1)(vi)Section 9(1)(vii)

…per the provisions of Section 44BB of the Act . 6 . Now, coming to the second issue relating to the service tax, learned AR placed reliance on the decision of the Hon'ble Jurisdiction High Court in the case of CIT vs. Mitchell Drilling International P. Ltd . 380 ITR 130 in support of his contention that the service-tax being statutory levy , should not form part of gross receipts as per provision of Section 44BB of the Act . He further placed reliance on the decision of the coordinate bench in the case of DDIT vs. Sundowner Offshore International (Bermuda) Ltd. ITA 1067/De1/2016 for a similar principle. We find…

ASSISTANT COMMISSIONER OF INCOME TAX, DEHRADUN vs. WESTERN GECO INTERNATIONAL LIMITED, HARYANA

The Appeal of the Revenue is dismissed

ITA 141/DDN/2024[2022-23]Status: DisposedITAT Dehradun31 Jul 2025AY 2022-23

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 141/Del/2024 (A.Y 2021-22)

Section 143(3)Section 44BSection 44DSection 9(1)(vii)

…orm part of aggregate amount referred to in clauses (a) and (b) of sub-section (2) of Section 44BB of the Act. To the similar effect is the decision of Hon’ble High Court in the case of Director Income- tax Vs. Mitchell Drilling International (P.) Ltd. [2016] 380 ITR 130 (Del.), wherein it was held that the service tax collected by the assessee for passing it on to Government was not to be included in gross receipt in terms of Section 44BB(2) read with Section 44BB (1) of the Act for the purpose of computing presumptive income of the assessee under Section 44BB of the Act. Respectfully following the decision of H…

A.G.T. ELECTRONICS LTD.,COIMBATORE vs. ADIT, CPC, , BENGALURU

In the result, the appeal of the assessee is allowed

ITA 2767/CHNY/2024[2018-19]Status: DisposedITAT Chennai17 Jun 2025AY 2018-19

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble S.R. Raghunathaआयकर अपील सं./ Ita No.2767/Chny/2024 िनधा8रण वष8 /Assessment Year: 2018-19

For Appellant: Shri S. Sridhar, Advocate (Erode)For Respondent: Ms. R. Anitha, Addl. CIT
Section 139(9)Section 143(1)Section 143(2)Section 143(3)Section 264Section 44A

…11 -: (i) State of A.P. Vs A.P. Paper Mills Ltd. [(2005) 1 SCC 719] (ii) State of Andhra Vs Shree Bajranga Jute Mill Ltd. [AIR 1955 AP 241] (iii) DCCT Vs Krishnaswamy Mudaliar and Sons [AIR 1954 Mad 8561] (iv) DIT-I Vs Mitchel Drilling International (P) Ltd. 380 ITR 130 (Delhi) (v) DIT-I Vs Schlumberger Asia Services Ltd. (2019) 414 1 (Uttarakhand) (vi) Eni India Ltd Vs JCIT, [2020] 116 taxmann.com 974 (Delhi-Trib]. 12. Under the given facts and situation, to arrive the turnover of business for the purpose of tax audit u/s 44AB of the Act, the rental income of Rs.2,48,55,598/- has to be deducted from the total…

DCIT (INTERNATIONAL TAXATION),CIRCLE-I, DEHRADUN vs. HALLIBURTON OFFSHORE SERVICES INC., DEHRADUN

ITA 6714/DEL/2017[2014-15]Status: DisposedITAT Dehradun07 May 2025AY 2014-15

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Salil Kapoor, Sh. S. LalchandaniFor Respondent: Sh. Mithun Shete, Sr. DR
Section 143(3)Section 44BSection 44DSection 9(1)(i)Section 9(1)(vii)

…form part of aggregate amount referred to in clauses (a) and (b) of sub-section (2) of Section 44BB of the Act. To the similar effect is the decision of Hon’ble High Court in the case of Director Income-tax Vs. Mitchell Drilling International (P.) Ltd. [2016] 380 ITR 130 (Del.), wherein it was held that the service tax collected by the assessee for passing it on to Government was not to be included in gross receipt in terms of Section 44BB(2) read with Section 44BB (1) of the Act for the purpose of computing presumptive income of the assessee under Section 44BB of the Act. Respectfully following the decision of H…

DCIT (INTERNATIONAL TAXATION),CIRCLE-I, DEHRADUN vs. HALLIBURTON OFFSHORE SERVICES INC., DEHRADUN

ITA 6171/DEL/2017[2013-14]Status: DisposedITAT Dehradun07 May 2025AY 2013-14

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Salil Kapoor, Sh. S. LalchandaniFor Respondent: Sh. Mithun Shete, Sr. DR
Section 143(3)Section 44BSection 44DSection 9(1)(i)Section 9(1)(vii)

…form part of aggregate amount referred to in clauses (a) and (b) of sub-section (2) of Section 44BB of the Act. To the similar effect is the decision of Hon’ble High Court in the case of Director Income-tax Vs. Mitchell Drilling International (P.) Ltd. [2016] 380 ITR 130 (Del.), wherein it was held that the service tax collected by the assessee for passing it on to Government was not to be included in gross receipt in terms of Section 44BB(2) read with Section 44BB (1) of the Act for the purpose of computing presumptive income of the assessee under Section 44BB of the Act. Respectfully following the decision of H…

HALLIBURTON OFFSHORE SERVICES INC.,NOIDA vs. DCIT (INTERNATIONAL TAXATION), CIRCLE-1, DEHRADUN

ITA 6026/DEL/2017[2013-14]Status: DisposedITAT Dehradun07 May 2025AY 2013-14

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Salil Kapoor, Sh. S. LalchandaniFor Respondent: Sh. Mithun Shete, Sr. DR
Section 143(3)Section 44BSection 44DSection 9(1)(i)Section 9(1)(vii)

…form part of aggregate amount referred to in clauses (a) and (b) of sub-section (2) of Section 44BB of the Act. To the similar effect is the decision of Hon’ble High Court in the case of Director Income-tax Vs. Mitchell Drilling International (P.) Ltd. [2016] 380 ITR 130 (Del.), wherein it was held that the service tax collected by the assessee for passing it on to Government was not to be included in gross receipt in terms of Section 44BB(2) read with Section 44BB (1) of the Act for the purpose of computing presumptive income of the assessee under Section 44BB of the Act. Respectfully following the decision of H…

ACIT, CIRCLE- II, INTERNATIONAL TAXATION , DEHRADUN vs. WEATHERFORD OIL TOOLS M.E. LTD., DEHRADUN

ITA 5696/DEL/2018[2015-16]Status: DisposedITAT Dehradun28 Apr 2025AY 2015-16

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Salil Kapoor, Sh. Anil ChachraFor Respondent: Sh. Mithun Shete, Sr. DR
Section 1Section 92D

…as per the provisions of Section 44BB of the Act. 6. Now, coming to the second issue relating to the service tax, learned AR placed reliance on the decision of the Hon'ble Jurisdiction High Court in the case of CIT vs. Mitchell Drilling International P. Ltd. 380 ITR 130 in support of his contention that the service-tax being statutory levy, should not form part of gross receipts as per provision of Section 44BB of the Act. He further placed reliance on the decision of the coordinate bench in the case of DDIT vs. Sundowner Offshore International (Bermuda) Ltd. ITA 1067/De1/2016 for a similar principle. We find th…

WEATHERFORD OIL TOOLS ME LTD.,DEHRADUN vs. ACIT, CIRCLE- II, INTERNATIONAL TAXATION, DEHRADUN

ITA 5647/DEL/2018[2015-16]Status: DisposedITAT Dehradun28 Apr 2025AY 2015-16

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Salil Kapoor, Sh. Anil ChachraFor Respondent: Sh. Mithun Shete, Sr. DR
Section 1Section 92D

…as per the provisions of Section 44BB of the Act. 6. Now, coming to the second issue relating to the service tax, learned AR placed reliance on the decision of the Hon'ble Jurisdiction High Court in the case of CIT vs. Mitchell Drilling International P. Ltd. 380 ITR 130 in support of his contention that the service-tax being statutory levy, should not form part of gross receipts as per provision of Section 44BB of the Act. He further placed reliance on the decision of the coordinate bench in the case of DDIT vs. Sundowner Offshore International (Bermuda) Ltd. ITA 1067/De1/2016 for a similar principle. We find th…

ACIT, CIRCLE- II, INTERNATIONAL TAXATION, DEHRADUN vs. WEATHERFORD OIL TOOLS M.E. LTD., DEHRADUN

ITA 417/DEL/2018[2014-15]Status: DisposedITAT Dehradun28 Apr 2025AY 2014-15

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Salil Kapoor, Sh. Anil ChachraFor Respondent: Sh. Mithun Shete, Sr. DR
Section 1Section 92D

…as per the provisions of Section 44BB of the Act. 6. Now, coming to the second issue relating to the service tax, learned AR placed reliance on the decision of the Hon'ble Jurisdiction High Court in the case of CIT vs. Mitchell Drilling International P. Ltd. 380 ITR 130 in support of his contention that the service-tax being statutory levy, should not form part of gross receipts as per provision of Section 44BB of the Act. He further placed reliance on the decision of the coordinate bench in the case of DDIT vs. Sundowner Offshore International (Bermuda) Ltd. ITA 1067/De1/2016 for a similar principle. We find th…

WEATHERFORD OIL TOOLS M.E. LTD.,NOIDA vs. DCIT, CIRCLE- 2, INTERNATIONAL TAXATION, DEHRADUN

ITA 7848/DEL/2017[2014-15]Status: DisposedITAT Dehradun28 Apr 2025AY 2014-15

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Salil Kapoor, Sh. Anil ChachraFor Respondent: Sh. Mithun Shete, Sr. DR
Section 1Section 92D

…as per the provisions of Section 44BB of the Act. 6. Now, coming to the second issue relating to the service tax, learned AR placed reliance on the decision of the Hon'ble Jurisdiction High Court in the case of CIT vs. Mitchell Drilling International P. Ltd. 380 ITR 130 in support of his contention that the service-tax being statutory levy, should not form part of gross receipts as per provision of Section 44BB of the Act. He further placed reliance on the decision of the coordinate bench in the case of DDIT vs. Sundowner Offshore International (Bermuda) Ltd. ITA 1067/De1/2016 for a similar principle. We find th…

ACIT, CIRCLE- II, INTERNATIONAL TAXATION, DEHRADUN vs. WEATHERFORD OIL TOOLS ME LTD., DEHRADUN

ITA 7477/DEL/2017[2013-14]Status: DisposedITAT Dehradun28 Apr 2025AY 2013-14

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Salil Kapoor, Sh. Anil ChachraFor Respondent: Sh. Mithun Shete, Sr. DR
Section 1Section 92D

…as per the provisions of Section 44BB of the Act. 6. Now, coming to the second issue relating to the service tax, learned AR placed reliance on the decision of the Hon'ble Jurisdiction High Court in the case of CIT vs. Mitchell Drilling International P. Ltd. 380 ITR 130 in support of his contention that the service-tax being statutory levy, should not form part of gross receipts as per provision of Section 44BB of the Act. He further placed reliance on the decision of the coordinate bench in the case of DDIT vs. Sundowner Offshore International (Bermuda) Ltd. ITA 1067/De1/2016 for a similar principle. We find th…

WEATHERFORD OIL TOOLS M E LTD.,DEHRADUN vs. DCIT, CIRCLE- 2, INTL. TAXATION, DEHRADUN

ITA 7334/DEL/2017[2013-14]Status: DisposedITAT Dehradun28 Apr 2025AY 2013-14

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Salil Kapoor, Sh. Anil ChachraFor Respondent: Sh. Mithun Shete, Sr. DR
Section 1Section 92D

…as per the provisions of Section 44BB of the Act. 6. Now, coming to the second issue relating to the service tax, learned AR placed reliance on the decision of the Hon'ble Jurisdiction High Court in the case of CIT vs. Mitchell Drilling International P. Ltd. 380 ITR 130 in support of his contention that the service-tax being statutory levy, should not form part of gross receipts as per provision of Section 44BB of the Act. He further placed reliance on the decision of the coordinate bench in the case of DDIT vs. Sundowner Offshore International (Bermuda) Ltd. ITA 1067/De1/2016 for a similar principle. We find th…

OCEANEERING INTERNATIONAL GMBH,MUMBAI vs. DCIT(INT. TAXATION)RANGE-3(2)(2), MUMBAI

ITA 802/MUM/2025[2022-23]Status: DisposedITAT Mumbai03 Apr 2025AY 2022-23

Bench: Shri Pawan Singh & Ms. Padmavathy S

For Appellant: Shri Abdul Kadir Jawadwala ARFor Respondent: Shri Krishna Kumar, Sr. DR
Section 143(3)Section 144C(13)Section 145ASection 153Section 254(1)Section 44B

…rovided by the assessee, which can form part of the gross receipts for the purposes of computation of gross income under Section 44BB(1) read with Section 44BB(2). DIT v. Mitchell Drilling International (P.) Ltd. [2015] 62 taxmann.com 24/234 Taxman 818/[2016] 380 ITR 130 (Delhi). On its literal construction, Section 44BB(2) would only be the amount paid by the ONGC to the assessee on account of (i) provision of services in connection with or (ii) supply of plant and machinery on hire used in, the prospecting, extraction and production of mineral oils. As the amount reimbursed by the ONGC, towards the service tax…

OCEANEERING INTERNATIONAL GMBH,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (IT) 3(2)(2), AIR INDIA BUILDING, MUMBAI

In the result, ground no. 2 of the assessee's appeal is allowed

ITA 4670/MUM/2023[AY 2021-22]Status: DisposedITAT Mumbai21 Mar 2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI VIKRAM SINGH YADAV (Accountant Member)

Section 143(2)Section 143(3)Section 153Section 234ASection 234BSection 234CSection 274Section 44B

…rovided by the assessee, which can form part of the gross receipts for the purposes of computation of gross income under Section 44BB(1) read with Section 44BB(2). DIT v. Mitchell Drilling International (P.) Ltd. [2015] 62 taxmann.com 24/234 Taxman 818/[2016] 380 ITR 130 (Delhi). On its literal construction, Section 44BB(2) would only be the amount paid by the ONGC to the assessee on account of (i) provision of services in connection with or (ii) supply of plant and machinery on hire used in, the prospecting, extraction and production of mineral oils. As the amount reimbursed by the ONGC, towards the service tax…

Showing 1–20 of 84 · Page 1 of 5

CIT v. Mitchell Drilling International P. Ltd. (380 ITR 130) — Cited in 84 Judgments | BharatTax