Taxes withheld by applying the provisions of section 44BB on payments to nonresident oilfield service provider not lead to breach of withholding tax provisions

Frontier Offshore Exploration (India) Limited Vs. DCIT ITA No. 200/Mds/2009 Facts :- The assessee is an Indian company and is engaged in the business of providing oilfield services to upstream companies. The assessee has entered into a contract with ONGC and M/s Hardy Exploration & Production India for drilling of oil wells in the territorial waters of India. For the purpose of executing this contract, the assessee took two drilling units owned by two foreign companies on bare boat charter basis. The assessee was required to pay the hire charges for the drilling units in the form of bare b...