Pitch and substance of each contract entered by NR Co. to be evaluated before examine applicability of sec. 44BB

INTERNATIONAL TAXATION : Where Assessing Officer characterized charter receipts earned by assessee, a non-resident company from provision of services of various vessels as royalty by denying specific exclusion granted for activities covered under section 44BB from definition of 'royalty' in Explanation 2 to section 9(1)(vi) on ground that no amounts were offered to tax under section 44BB by assessee, since Assessing Officer has not examined applicability of section 44BB by looking into whether p

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