Assessee, a Denmark based company, was engaged in business of shipping and logistics.  During relevant year assessee received reimbursement of cost from its Indian group concern towards business support charges which was claimed as not liable to tax due to absence of assessee’s PE in India  Assessing Officer held that  support services were ancillary and subsidiary to providing access to IT Network Systems of goods, brought amount in question to tax as fee for technical services under article 13 of India-Denmark DTAA. Tribunal held that reimbursement of cost was towards administrative services, same could not be held to be in nature of technical, managerial and consultancy services and, thus, amount received by assessee was not taxable as fee for technical services. (AY. 2012-13, 2013-14)