Held that the Assessee, a Singapore based company has not allowed use of its commercial or scientific experience or use or right to use any copyright of literary, artistic or scientific work or any patent, trade mark, design or model, plan, secret formula or process to the Indian company ATS while rendering project related services which involved simply mailbox hosting services and data center services through serves located outside India and, therefore, the payment received by the assessee for rendering said services relating to various projects did not constitute royalty under art. 12(3) of the Indo-Singapore DTAA. Tribunal also held that  since there is nothing to suggest that ATS can use any technical knowledge, experience, skill, know-how or process independently on its own without the involvement of the assessee, the conditions of art. 12(4)(b) of the DTAA are not satisfied  therefore, the payment received by the assessee did not qualify as fees for technical services either. (AY.2014-15, 2015-16)