Charter Hire Charges: Royalty or Section 44BB Income? Mumbai Tribunal Orders DRP to Reconsider

Celestial Vision Limited Vs ACIT (ITAT Mumbai) Charter Hire Charges: Royalty or 44BB Income? – DRP Mixed Up Facts & Ignored Core Issue- Mumbai Tribunal Sends Back for Fresh Decision Celestial Vision Ltd, a company incorporated in the British Virgin Islands (BVI), filed its return for AY 2022-23 declaring income of ₹89.64 lakh u/s 44BB on presumptive basis, claiming that receipts of ₹8.96 crore represented charter hire charges for equipment used in oil exploration activities. AO rejected this, holding that the receipts were in the nature of “royalty” u/s 9(1)(vi) r.w. Explanat...