Assessee, a tax resident of USA, was engaged in business of maintaining online data base (Lexis Nexis) pertaining to legal and law related information.  It received subscription fee for providing access to data base-Since assessee had no PE in India, it filed return of income by treating subscription fee received for providing access to data base as business income, not taxable in India as per provisions of India-US DTAA.  Assessing Officer,  treated receipt of assessee as FIS on ground that same was in nature of technical consultancy.  Tribunal held that subscription fee received by assessee was in nature of business profit which could not be brought to tax in India in absence of Permanent Establishment (PE). On appeal the Court held that   access to data base did not constitute rendering of any technical or consultancy services and in any case did not amount to technical knowledge, experience, skill, know-how or processes being made available to subscriber neither there was any transfer of copyright. Order of Tribunal is affirmed.(AY. 2018-19, 2019-20)