Receipts on account of identification & core site selection from available 2D & 3D seismic data shall be taxed U/s. 44BB

The assessee received revenue on account of the contract entered into with ONGC for providing services of seismic survey to the data correction supervision for the purpose of hydrocarbon reservoir exploitation, possible leak point identification and core site selection from available 2D and 3D seismic data, core acquisition with USBL System, sample processing, prevention and transportation, laboratories analysis and interpretation and report. During the course of assessment proceedings, the assessee was asked to explain why looking at the nature of services, receipt may not be treated as fees ...