OIL & NATURAL GAS CORPORATION LIMITED vs COMMISSIONER OF INCOME TAX-I

Whether the exemption notification No.GSR 307(E) dated 31.03.1983 issued under Section 24AA of the Companies (Profits) Surtax Act, 1964, granting surtax exemption to foreign companies with whom the Central Government has entered into agreements for association or participation in the business of prospecting for, extraction, or production of mineral oils, also extends to foreign companies providing services, facilities, or supplying ships, aircraft, machinery, or plant in connection with such business, as covered under Section 24AA(2)(b) of the Surtax Act --- Held No.