Held, that the intermediary services rendered by the assessee did not make available any technical knowledge and skill to BTIN and BTIN was not equipped to apply technology contained in the services rendered by the assessee. Therefore, the intermediary services did not amount to fees for technical services and were not taxable in India. Only income that is attributable to the operations carried out in India can be taxed in India. The Dispute Resolution Panel held that BTIN was the permanent establishment of the assessee in India without appreciating the true facts that the assessee had no place of disposal in India in the office of BTIN from where the assessee could have conducted its business in India. Therefore, the Assessing Officer was  directed to delete the addition of income attributable to permanent establishment. (AY. 2011-12)