Assessee, a Singapore based company, was engaged in business of providing/sub-licensing software to entities in financial service sector. It earned revenue from maintenance services and training services provided to its Indian customers-Assessing Officer held that assessee provided training services related to basic use of its company’s software. CIT(A) deleted the addition. On appeal the Tribunal held that income earned was FTS as per DTAA on ground that technical knowledge, experience, and skill possessed by assessee with regard to various aspects were made available in form of advice or services, which were finally used by Indian customers. It was noted that Tribunal in assessee’s own case for assessment year 2018-19, held that maintenance services and training services provided by assessee to Indian customers did not fall within ambit of FTS under article 12 of India-Singapore DTAA as services did not make available any technical skills, knowledge, or expertise etc., which enabled Indian customers to apply technology contained therein, and therefore income of assessee from rendering services was not taxable in India. Following same,  income earned by assessee from maintenance services and training services was not taxable in India. (AY. 2015-16 2016-17, 2017-18)