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    <title>2025 (1) TMI 384 - ITAT DELHI</title>
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    <description>Reassessment was sustained despite a minor discrepancy in the recorded escapement figure because the reopening remained grounded in alleged income escaping assessment. Receipts for drawings and designs supplied to Indian customers were not upheld as taxable as fee for technical services on the facts and contract terms, so the addition was deleted. Supervisory receipts required verification because taxation depended on the contract completion method and whether the income had already been offered in the year of completion; the matter was remitted for limited factual inquiry.</description>
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