Assessee, a German company, which is engaged in business of supply of plant, equipment, drawings and rendering of technical services to customers in metallurgical sector.  During year under consideration, assessee entered into various contracts with Indian clients for supply of drawings and designs in relation to plant from Germany and rendering of technical services. Assessee offered receipts from drawings and designs and technical services as fee for technical services’ (FTS) at rate of 10 per cent as per DTAA between India and Germany.  Assessing Officer held that  the assessee had not offered to tax receipts from one Indian company (JSPL).  Accordingly, he proceeded to reopen assessment and brought to tax receipts from one Indian company at 10 per cent as FTS. On appeal following the order of the sister concern  since provisions of royalties and FTS are similar in nature, Assessing Officer was to be directed to delete addition. As regards supervisory services  the assessee following the  contract competition method  the issue is  remanded to the Assessing Officer. (AY. 2005-06, 2014-15, to 2017-18)