The assessee received certain assets free of cost from its overseas AEs on a returnable basis. These were testing equipment/prototypes provided to ensure software development services met required parameters. Assets were either returned to AEs or destroyed after completion of projects. The assessee had an Advance Pricing Agreement (APA) that already considered depreciation on these assets in the cost base for determining transfer pricing. Training services couldn’t be classified as technical, managerial or consultancy services. These services fell under Article 14 (Independent Personal Services) of India-Singapore DTAA and hence not taxable. (AY. 2017-18)