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TMI Blog2020 (8) TMI 475X X X X Extracts X X X X X X X X Extracts X X X X ..... ec. 44DA r.w. Section 115A of the Act - HELD THAT:- The said questions of law have already been answered by the order in ONGC vs. CIT. [2015 (7) TMI 91 - SUPREME COURT] . In terms whereof, the substantial questions of law were answered in favour of the assessee and against the revenue. The said position is not disputed by both the learned counsels. Decided in favour of assessee - Income Tax A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 44DA r.w. Section 115A of the Act. (2) Whether on the facts and in the circumstances of the case, the Hon'ble ITAT has erred holding that the revenues earned by the assessee on account of conduct of seismic surveys were in connection with prospecting etc. Of mineral oil and hence eligible for treatment u/s 44BB of the Act, without adjudicating the aspect of eligibility under the second l ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ation of Royalty Fee for Technical Services are disregarding the insertion of provisos in section 44BB/44DA/115 and the rationale behind the introduction of said claificatory provisos in the Finance Bill 2010 in holding that the income of the assessee company was covered under the provisions of Section 44BB. (5) Whether on the facts and in the circumstances of the case, the Hon'ble ITAT ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he contentions, it transpires that the said questions of law have already been answered by the order of the Hon'ble Supreme Court of India in 376 ITR 306 (Supreme Court) ONGC vs. CIT. In terms whereof, the substantial questions of law were answered in favour of the assessee and against the revenue. The said position is not disputed by both the learned counsels. 3. In view thereof, the appea ..... X X X X Extracts X X X X X X X X Extracts X X X X
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