IPRs under Indian laws only are taxable; appellant secures waiver on non-Indian IPRs per C.B.E. & C. clarification.

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....Only those IPRs procured under Indian laws are to be covered under IPR services and those IPRs not covered by the Indian Laws would not be covered under taxable under IPR Services. In view of clarification issued by C.B.E. & C. appellant has made out a prima facie case for complete waiver - AT....