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Sec. 44BB being specific provision would prevail over provisions dealing with royalty/FTS: Delhi ITAT

April 16, 2018[2018] 92 77 (Delhi - Trib.)/[2018] 170 ITD 468 (Delhi - Trib.)

IT/ILT: Sections 9, 44BB, 44DA and 115A relating to royalty/FTS operate in different fields; where assessee is imparting services which could be a simple royalty or FTS, then same would be taxed under section 9(1)(vi)/(vii) read with section 115A, but where assessee is imparting any services in relation to exploration of mineral oil then royalties/FTS would be taxable under section 44BB

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