The assessee, a Singapore company, rendered regional managerial and administrative services to its Indian affiliate under a Regional Services Agreement on a cost-sharing basis. The Tribunal held that the services involved the application of expertise and not the transfer of know-how or intellectual property. The receipts constituted business profits under Article 7 and, in the absence of a permanent establishment in India, were not taxable as royalty under Article 12. (AY. 2017-18 to 2020-21).