https://www.taxtmi.com/caselaws?id=768880 Receipts for drawings and designs, where contractually and commercially inseparable from offshore supply of plant and equipment, could not be taxed independently as fees for technical services; the offshore supply was treated as completed outside India and the additions were deleted. Reimbursements of SAP, intranet and related charges were not fees for technical services or royalty, so the addition was deleted. For the non-resident assessee, section 234B interest was held not leviable for the relevant years, but the section 263 revision for AY 2007-08 was sustained because the original assessment had not examined the contracts and agreements in detail. en-us Wed, 09 Apr 2025 00:00:00 +0530 Tue, 15 Apr 2025 08:35:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768880 Receipts for drawings and designs, where contractually and commercially inseparable from offshore supply of plant and equipment, could not be taxed independently as fees for technical services; the offshore supply was treated as completed outside India and the additions were deleted. Reimbursements of SAP, intranet and related charges were not fees for technical services or royalty, so the addition was deleted. For the non-resident assessee, section 234B interest was held not leviable for the relevant years, but the section 263 revision for AY 2007-08 was sustained because the original assessment had not examined the contracts and agreements in detail. Case-Laws Income Tax Wed, 09 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768880