https://www.taxtmi.com/caselaws?id=768880 The ITAT Delhi held that income from supply of designs and drawings forming integral part of equipment sale/supply was not taxable in India, following consistent coordinate bench decisions from AY 1992-93 onwards. Reimbursements for SAP software installation, maintenance, and intranet charges were not taxable as "fees for technical services" under section 9(1)(vii), as no technical services were provided. The tribunal directed verification of design/drawing details within three opportunities, placing burden of proof on assessee. Interest charges under section 234B for non-residents were deleted, following SC precedent in DIT vs. Mitsubishi Corporation, which held section 209(1) proviso has prospective effect only from Finance Act 2012. en-us Wed, 09 Apr 2025 00:00:00 +0530 Tue, 15 Apr 2025 08:35:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768880 The ITAT Delhi held that income from supply of designs and drawings forming integral part of equipment sale/supply was not taxable in India, following consistent coordinate bench decisions from AY 1992-93 onwards. Reimbursements for SAP software installation, maintenance, and intranet charges were not taxable as "fees for technical services" under section 9(1)(vii), as no technical services were provided. The tribunal directed verification of design/drawing details within three opportunities, placing burden of proof on assessee. Interest charges under section 234B for non-residents were deleted, following SC precedent in DIT vs. Mitsubishi Corporation, which held section 209(1) proviso has prospective effect only from Finance Act 2012. Case-Laws Income Tax Wed, 09 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768880