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 decision that such payments are chargeable under Section 44D, thereby affirming the view of the assessing authority. The judgment clarifies the applicability of different sections of the Income Tax Act in the context of international taxation.