U.O.I. And Ors vs Keshar Singh

The Supreme Court addressed whether payments made by ONGC to foreign companies for services related to mineral oil extraction are taxable as 'fees for technical services' under Section 44D and Explanation 2 to Section 9(1)(vii) of the Income Tax Act, or under Section 44BB on a presumptive basis. The Court upheld the High Court's ruling that these payments are chargeable under Section 44D, emphasizing the nature of the agreements and the services rendered. Consequently, the appeals by ONGC were dismissed, affirming the High Court's decision.