Sum received by NR from sale of designs & drawings to Indian customers for internal purpose is business income

INTERNATIONAL TAXATION : Where assessee a foreign company, had primarily earned revenue from sale of designs and drawings to Indian customers, since designs and drawings were used by Indian customers for internal business purposes for setting up of their plants and not for any commercial exploitation, designs and drawings sold by assessee tantamounted to use of copyrighted article rather than use of a copyright and was, therefore, business income

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