Income from offshore sale of products could not be construed to be FTS or royalty liable to tax in India. Repair work undertaken by assessee at its overseas workstations located outside India and since it was in connection with supply of plant and machinery on hire to be used for extraction or production of mineral oils, same would clearly fall within sweep of exclusion contemplated in Explanation 2 to s. 9(1)(vii). Since rendering of repair work by assessee outside India would not enable ONGC personnel to make use of any technical knowledge, experience in future, amount received by assessee could not be brought to tax as ‘royalty’ or ‘fee for technical service’ under article XII(3) of India-Australia DTAA. Since various activities undertaken by assessee under contract with ONGC were seperate, divisible and independent of each other, taxability of revenue from such activities was required to be undertaken separately.