Oil & Natural Gas Corp. Ltd vs Commnr. Of Income Tax & Anr

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 decision that these payments are chargeable under Section 44D, emphasizing the nature of the services rendered as technical in nature. Consequently, the appeals by ONGC were dismissed, affirming the High Court's ruling.