Payment for Technical Services, Not Royalty: Austrian Company Supplies Designs; Project Executed in Austria, No Royalty Involved.

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Full Text of the Document

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....Royalty V/S fee for technical service - All products, design of the engines and vehicles are supplied by the assessee. On completion all the drawings are also delivered by the Austrian company to the assessee. The entire project was carried out in Austria - the payment does not constitute royalty.....