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    <description>Legal representation before foreign courts did not constitute fees for technical services or fees for included services because the work did not make available technical knowledge, skill or experience for future independent use; the receipts were therefore outside section 9(1)(vii) of the Income-tax Act, 1961. Maintenance services for a high-resolution CT scanner used in oil-related research were directly and inextricably connected with prospecting and production of mineral oil, so the receipts fell within the presumptive regime under section 44BB and not as fees for technical services. The additions treating both receipts as taxable fees for technical services were set aside.</description>
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