Royalties/Fee for technical services – Design, Drawing and documentation : Where assessee, a tax resident of Switzerland, had entered into composite contracts for supply of design and engineering and supply of plant and equipment, since both contracts were inextricably linked and income from supply of plant and equipment was held to be not taxable in India, amount received by assessee from supply of drawings and designs was not also taxable in India as FTS – Andritz AG v. DDIT (International Taxation) – [2024] 165 taxmann.com 76 (Delhi – Trib.)
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