Cost of reworking reimbursed to NR wasn't FTS as re-working done abroad had no link with business of

IT/ILT : Where assessee engaged in manufacturing and export of printed circuit boards, paid certain repairing expenses to its parent company located abroad to complete manufacturing process before selling its products to final customers, since activities carried out outside India had no connection with assessee's operations in India, payment in question was not taxable in India under section 9(1)(vii)