https://www.taxtmi.com/caselaws?id=439891 Where drawings and designs are supplied outside India as part of a composite equipment contract and are inseparably linked to the manufacture and supply of plant, the receipt is treated as part of the supply and not as fees for technical services; the amount was therefore not taxable in India. By contrast, supervisory services for erection and commissioning involving deputation of qualified technical personnel fell within the definition of fees for technical services under domestic law and the treaty, so the receipt remained taxable in India. The result was partial relief: the assessee succeeded on the drawings and designs issue but failed on the supervisory services issue. en-us Fri, 16 Jun 2023 00:00:00 +0530 Mon, 04 Mar 2024 16:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=439891 Where drawings and designs are supplied outside India as part of a composite equipment contract and are inseparably linked to the manufacture and supply of plant, the receipt is treated as part of the supply and not as fees for technical services; the amount was therefore not taxable in India. By contrast, supervisory services for erection and commissioning involving deputation of qualified technical personnel fell within the definition of fees for technical services under domestic law and the treaty, so the receipt remained taxable in India. The result was partial relief: the assessee succeeded on the drawings and designs issue but failed on the supervisory services issue. Case-Laws Income Tax Fri, 16 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=439891