Business of providing services in connection with the prospecting for or extraction or production of mineral oil governed by Section 44BB

RELEVANT PARAGRAPH 6.1. We are of the view that the case of the applicant neatly fits into Section 44BB and all the ingredients of that section are satisfied. To attract the first part of section 44BB, the non-resident must be (a) engaged in the business of providing services or facilities; (b) such provision of services/ facilities must be ‘in connection with’ the prospecting for or extraction or production of mineral oils. Both these ingredients are present in relation to the activities undertaken by the applicant in India. Firstly, it does not admit of any doubt that the applicant is en...