AAR held that  the solutions provided by the applicant were neither specialized nor exclusive and did not cater to individual requirements of the customer. The solutions were offered by the applicant through its platform and they remained the same for all customers who availed of the applicant’s facility, irrespective of the business or website content. The solutions provided by the applicant without human intervention could not be treated as provision of technical services. The payments received by the applicant from the Indian company for content delivery solutions were outside the scope of “fees for technical services” within the meaning of Explanation 2 to section 9(1)(vii) of the Act.AAR also held that the payment received cannot be assessed as royalty .As the assessee did not have any permanent  establishment in India . Accordingly not liable to deduct tax at source .