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2009 (3) TMI 84 - CESTAT MUMBAIRefund claim for the period 01/01/2004 to 09/09/2004, by the recipient of Consulting engineer's service, on the royalty amounts paid to their foreign collaborators - payments made after 10/09/2004 were also of this nature and no claim for refund thereof has been made by them – held that the services received by the appellants from the foreign company were to be classified as 'consulting engineer's service' – held that, it is not open to the appellants to deviate from their stand that they were receiving consulting engineer's service from abroad under the agreement for a part of the period - appellants are estopped from construing the provisions of the agreement for a part of the period – refund denied
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