Assessee, a US company, was engaged in business of providing repair and maintenance services of aircraft equipment. During relevant year, assessee received certain amount towards repair and maintenance services from Indian airline operators. Assessing Officer held  that said receipts were chargeable to tax as fees for technical services (FTS) under Act as well as India-USA DTAA. DRP affirmed the order of the Assessing Officer. On appeal Tribunal  held that  services rendered by assessee did not involve any transfer of technology, know-how or skill hence receipts from repair and maintenance services were not taxable as FIS under article 12(4) of India-USA DTAA. High Court affirmed the order order of the Tribunal. (AY. 2018-19)