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21. In this context, we think it appropriate to refer to the decision rendered in the case of De Beers India Minerals Pvt. Ltd. (supra). In the said case, the Dutch company performed services using technical knowledge and expertise and it had given data, photographs and maps to assessee but they did not make available technical expertise, skill or knowledge in respect of collection 12 HSBC Bank Plc or processing of data to assessee, which assessee could apply independently without assistance and undertake such survey independently to the exclusion of Dutch company in future. The Hon'ble High Court held that payment made for services in question could not be termed as 'Fees for Technical Services'. In fact, the Hon'ble Karnataka High Court in the case of De Beer India Minerals Pvt. Ltd. (supra) has succinctly adumbrated the position in the following discussion :-