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    <title>2019 (6) TMI 777 - ITAT KOLKATA</title>
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    <description>Receipts from sale of designs and drawings were treated as business income because the contracts showed sale of a product, not grant of a right to exploit copyright or technical know-how; as the work, sale, and consideration were outside India and no permanent establishment existed, the receipts were not taxable in India. Receipts from testing and related services were held taxable in India under the India-Finland DTAA because the payment was for test results and benefits used in India, and the treaty deeming rule for fees for technical services applied despite the services being performed outside India. The addition on designs and drawings was deleted, while taxability of the service receipts was upheld.</description>
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