Seismic survey services in connection with oil exploration is not in nature of FTS/Royalty

PGS Geophysical As Vs Income Tax Department (Delhi High Court) Delhi High Court held that seismic survey services in connection with exploration of oil cannot be held to be in nature of Fees for Technical Services [FTS]/Royalty and hence not covered under section 44DA of the Income Tax Act. Accordingly, writ petition is allowed. Facts- The petitioner is a non-­resident company and is incorporated in Norway. It is engaged in the business of providing geophysical services to oil and gas industry. It conducts seismic surveys and provides offshore seismic data acquisition and other associated se...