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    <description>Payments for technical drawings and designs supplied to a non-resident parent company were treated as purchases of copyrighted articles on a principal-to-principal basis, with no transfer of copyright rights; on that footing, the amounts were not royalty and no tax deduction at source arose under section 195 or exposure under section 201. The commentary also notes that disallowances and additions for foreign travel, training, vehicle hire, estimated project profits, accrued interest, warranty provision, excise duty, sales tax, ad hoc expenses, and bad debts depend on business purpose, supporting records, mercantile accounting, and the absence of specific defects in the books. Warranty provisions, written-off bad debts, and bona fide business expenditures were considered allowable.</description>
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