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    <title>2025 (3) TMI 2101 - ITAT DELHI</title>
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    <description>Consideration for drawings and designs supplied with offshore plant and equipment was treated as integral to the equipment supply rather than taxable fees for technical services in India. Although covered by separate contracts, the contracts were executed on the same date, were commercially inseparable, and the drawings could not be independently used without the equipment. Their preparation, supply and payment occurred outside India, and termination of the equipment contract could terminate the drawings-and-designs contract. On identical facts, the consideration was not taxable in India as fees for technical services.</description>
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      <link>https://www.taxtmi.com/caselaws?id=470435</link>
      <description>Consideration for drawings and designs supplied with offshore plant and equipment was treated as integral to the equipment supply rather than taxable fees for technical services in India. Although covered by separate contracts, the contracts were executed on the same date, were commercially inseparable, and the drawings could not be independently used without the equipment. Their preparation, supply and payment occurred outside India, and termination of the equipment contract could terminate the drawings-and-designs contract. On identical facts, the consideration was not taxable in India as fees for technical services.</description>
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