S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-No material on record to demonstrate that assessee made available technical knowledge, skill, experience and know-h ow-Commissioner (Appeals) attributing 50 Per Cent. of receipts to consultancy services based on estimate and without any reasonable basis-Addition not sustainable-DTAA-India-UK [ art. 12(3)(b), 13(4) (c ) ]