Assessee made remittances to party in Mexico for clinical trials. Assessing Officer held that assessee was liable to deduct taxes on said remittances as same were fees for technical services.  Commissioner (Appeals)  held that assessee would not fall within second exception provided under section 9(1)(vii)(b) on ground that all activities related to business of assessee were carried out in India and merely doing export activity from India could not be treated as business carried outside India. Held that  since payments made by assessee were not covered by exception provided under section 9(1)(vii)(b) and there was absence of ‘make available’ clause in India-Mexico DTAA, services rendered to assessee would qualify as FTS/FIS and, thus, tax was to be deducted at source at time of payment of said services. (AY. 2013-14)