ORDER

Per Satbeer Singh Godara, Judicial Member:

This assessee’s appeal for Assessment Year 2013-14, arises against the CIT(A)-43, New Delhi’s case No. 91/2016-17 dated 17.08.2016, in proceedings u/s 143(3) of the Income Tax Act, 1961 (in short “the Act”).

2. Heard both the parties at length. Case file perused.

3. The assessee pleads the following substantive grounds in the instant appeal:

“1. That the order of learned Commissioner of Income- tax (Appeals) [CIT (A)] is bad both in law and on facts of the case.

2.(a) That the learned CIT (A) has erred in law and on facts in holding that consideration received for supply of drawings and designs amounting to Rs. 2,73,65,708/- forming an integral part of the supply of equipment, received under various contracts is taxable as “Fees for Technical Services”.

(b) That the learned CIT (A) has failed to appreciate that on the facts and material on record, the receipts constituted “Business Profits” not accruing, arising or received in India or deemed to accrue or arise or received in India.

(c) That the learned CIT (A) has erred in not accepting that supply of drawings and designs was inextricably linked to sale of plant and equipment and represen